Fourth Five-Year Review Report for the Geneva Industries/Fuhrmann Energy Superfund Site Houston, Harris County, Texas September 3, 2013 Prepared By U.S. Environmental Protection Agency Region 6 1445 Ross Avenue Dallas, TX 75202-2733 _______________________________ ________________________ Carl Edlund Date: September 2013 Director Superfund Division U.S. Environmental Protection Agency Region 6
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Carl Edlund Date: September 2013 Director Superfund Division U.S. Environmental Protection Agency Region 6
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FOURTH FIVE-YEAR REVIEW
GENEVA INDUSTRIES/FUHRMANN ENERGY SUPERFUND SITE EPA ID# TXD980748453
Houston, Harris County, Texas This memorandum documents the U.S. Environmental Protection Agency's (EPA) performance of the Geneva Industries/Fuhrmann Energy Superfund Site Fourth Five-Year Review under Section 121 (c) of the Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S.C. § 9621(c). Background The Geneva Industries site is approximately 13.5 acres and is located at 9334 Canniff Road in Houston, Texas. The site is less than 1 mile east of Interstate Highway 45 and approximately 2 miles east of Hobby Airport. The primary land uses near the site are industrial and residential. Some residences are located less than 50-feet from the site boundary. The site and surrounding area are flat and have a maximum surface elevation of approximately 35 feet above mean sea level. The site is drained by the Harris County Flood Control District Channel, which runs along the eastern boundary of the site. The channel flows in a northerly direction into Berry Bayou. The Geneva site was a petrochemical production facility from 1967-1978. The facility produced a variety of organic compounds, including biphenyl, polychlorinated biphenyls (PCBs), phenyl phenol, naphtha, and No. 2 and 6 fuel oils. As of 1981, the site and adjoining property to the south contained processing tanks and piping, a large wastewater lagoon, two smaller lagoons, a closed lagoon holding solid PCB-containing wastes, a diked tank area, several drum storage areas, a landfill, and a possible landfarm. As a result of past practices at the site, extensive soil and shallow groundwater contamination existed at the site. A Planned Removal was performed by EPA from October 1983 to February 1984 to close out all three lagoons, remove all drummed waste on the surface, remove all off-property soils containing greater than 50 ppm PCBs, install a cap over all on-property soils containing greater than 50 ppm PCBs, and improve site drainage. Approximately 3,400 cubic yards of contaminated soil and sludge, 550 drums of waste, and 30 tons of asbestos were removed and transported to an approved facility in Emmelle, Alabama. Other removal actions to plug abandoned wells and remove storage tank materials were performed in May and September 1984, respectively. A Remedial Investigation/Feasibility Study (RI/FS) was performed from September 1984 to December 1985. EPA organized the work for this site into two Operable Units (OUs): soil (OU-1) and groundwater (OU-2). The Record of Decision (ROD) for the site was signed September 18, 1986. The remedy selected in the ROD included the following components:
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;
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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.
In July 1993, EPA issued an Explanation of Significant Differences (ESD) that raised the remedial goal for
TCE from 1.0 g/L to 5.0 g/L, bringing it in line with the promulgated Maximum Contaminant Level (MCL) for TCE. In May 2007 EPA issued an ESD which changed the selected remedy to include an institutional control (IC), enforceable by TCEQ, as a component of the overall remedy. All other components of the original selected remedy remain unchanged. The expected outcome of this IC is that the property deed information reflects the current site status and identifies the use of the site property as follows:
No digging on the capped area; No activities that will cause erosion or disrupt the integrity of the cap or landfill; No use, for any purpose, of the ground water from the 30-foot sand unit and the 100-foot sand
unit; No water wells of any kind drilled within the cap or landfill; and No residential use.
The remedial action for OU-1, consisting of soil excavation and disposal, and construction of the slurry wall and cap, was completed on September 28, 1990. Construction of the ground water recovery and treatment system was completed in April 1993. Following testing, groundwater recovery and treatment began in July 1993. A cutoff slurry wall that surrounds the perimeter of the site is in place to help prevent migration of affected groundwater from inside the wall, with inward gradients across the wall maintained by a groundwater extraction system. The operations and maintenance (O&M) of the site is ongoing; O&M activities include pumping of affected groundwater, treatment and discharge onsite of the extracted groundwater, performance and compliance monitoring to ensure the remedial action continues to perform as planned, and maintenance of the cap, slurry wall, and onsite groundwater treatment plant. The pump and treat system appears to be maintaining an inward gradient to the site most of the time, as intended, and the system is currently controlling the horizontal migration of contaminated groundwater in the 30-foot sand unit. Groundwater monitoring over the past five years shows that PCB contaminated groundwater has migrated from the 30-foot sand unit to the lower 100-foot sand unit, and PCB has been detected in the aquifer units below the 100-foot sand. There currently is no remediation or containment of the contaminated groundwater in the 100-foot sand unit, and if no action is taken it is expected that off site and vertical migration of contaminated groundwater will increase. Summary of Fourth Five-Year Review Findings This fourth five-year review includes the following components: (1) document review, (2) data review, (3) applicable or relevant and appropriate requirements (ARARs) review, (4) site inspection, and (5) interviews. During this five-year review, the following issues are noted:
1. PCB concentrations exceed the MCL and are increasing in the 100-foot sand unit. 2. No cleanup criteria has been established for PCB in the groundwater.
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3. There is no remediation or containment of the PCB contaminated groundwater in the 100-foot sand unit.
4. There is insufficient treatment plant capacity to treat pumped groundwater from both the 30-foot sand and 100-foot sand units.
5. There has been sporadic operation of the recovery/treatment system and groundwater elevation gauging during the review period.
6. PCB concentrations appear to be increasing in MW-24 at the eastern boundary of the site in the 100-foot sand unit and PCB contaminated groundwater may be leaving the site boundaries at levels exceeding the MCL.
7. Institutional controls mandated in the 2007 ESD have not been implemented at the site. 8. Groundwater contained within the slurry wall in the 30-foot sand is contaminated with volatile
organic compounds BTEX and TCE. The treatment system building is adjacent to the slurry wall on site and there is a possibility of vapor intrusion in the building at levels above those protective of human health.
9. Due to the shallow depth to groundwater of the 30-foot sand unit along the eastern boundary of the site and the detected contaminants in MW-26, there is a possibility that contaminated groundwater from the 30-foot sand unit has discharged into the Harris County flood control channel.
10. Based on the current information showing the groundwater flow direction in the 100-foot sand unit is to the north, there may be insufficient groundwater monitoring along the northern boundary of the site.
11. None of the monitoring wells have locks on the casing covers. The old recovery wells (RW-01 through RW-05 and RW-7 through RW-10) now used as piezometers do not have caps. Monitoring wells MW-02, MW-23 and MW-25 are missing bollards.
12. Two monitoring wells, MW-18 and MW-02, were identified during the site inspection as being lost or abandoned.
13. No O&M log was found during the site inspection. 14. The soil has eroded out from beneath the well pad at RW-03. 15. East of the deep monitoring wells, brackets holding the conduits on the stands have failed. 16. Fire ant mounds were observed on the cap which could create a conduit between the ground
surface and the buried wastes. 17. Site documents are missing from the local site information repository, the M.D. Anderson Library
on the main campus of the University of Houston. 18. The March 31, 2009 sample from the CWST exceeded the PCB discharge criteria. The water was
resampled on April 30, 2009 and was reported to meet the discharge criteria. This review was unable to confirm that the resampled results met the discharge criteria because the analytical results were not provided.
19. There is erosion control fabric exposed at the surface at the toe of the cap at the southeast corner.
20. The grate covering the floor drainage channel in the treatment plant is bent and presents a tripping hazard.
21. Currently reported well depths given for MW-101 and MW-102 do not match the depths given in the original 1985 well schematics, and it appears the labels for these two wells have been switched at some point in the past. The labels for the other two deep wells MW-103 and MW-104 may have been switched also.
Actions Needed In order to remain protective for the long-term, the following actions are required:
1. An nvestigation of the possible mechanisms for PCB entering the deeper water bearing units sh uld be conducted with the goal of mitigating the downward migration of PCB from the 30-foot sa d unit. The investigation should include the possibility that the deep monitoring wells are the so rce of the downward migration of PCB.
2. Th ROD should be amended with an ESD or ROD amendment to include a cleanup criteria for PC in groundwater.
3. Re overy and treatment of PCB contaminated groundwater in the 100-foot sand unit should be co ducted to prevent the further migration of PCB.
4. Th capacity of the treatment plant needs to be increased. An optimization study should be co ducted to determine the best method of increasing the plant capacity.
5. Th re has been sporadic operation of the recovery/treatment system and groundwater elevation ga ging during the review period. The recovery/treatment system needs to be operated on a co sistent basis to maintain an inward gradient of the contaminated 30-foot sand unit within the slu ry wall to prevent migration of contaminants off site. Groundwater elevation gauging is ne ded at least quarterly as recommended in the last five-year review to confirm the inward gr ient is being maintained.
6. Ve ify that no groundwater use is occurring in the 100-foot sand unit in the area of MW-24. If PCB co centrations continue to exceed the MCL at MW-24, consideration should be given to installing ad itional groundwater monitoring wells downgradient of MW-24.
7. Im lement ICs as mandated in the 2007 ESD. 8. A por intrusion screen should be performed on the site treatment system building. 9. An evaluation of the potential for contaminated groundwater from the site to discharge to the
Ha ris County flood control channel should be conducted. If there is a potential for this to occur, sa piing and analysis of the channel sediments and surface water for site contaminants should be onducted to verify the sediments and surface water are protective of human health and the en ironment.
10. An evaluation should be made of the groundwater flow direction in the 100-foot sand unit, and a de rmination made as to the sufficiency of the number and location of monitoring wells along the no hem boundary of the site.
Protective ess Determination:
I have det mined that the remedy for the Geneva Industries/Fuhrmann Energy Superfund Site is protective f human health and the environment in the short term, and will remain so provided the action items iden tied in the Fourth Five-Year Review Report are addressed as described above.
Date Director Superfund ivision
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1 Routing a d Concurrence Slip
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Begin Routing Da~p9t11 /2013 Routing Status: High ' J
Office:j n Remedial Branch - Arkansas/Texas Section
racking Category: I Five-Year Review
I
_ ent Confidential :! 0 Yes e No Email Subject: Geneva Five Year Review
Due Date:' 09/25/2013
D/DDD Assigned:J DD/DOD Status:] Pending
DD/ODD Remarks:J Fro t Office Ass igned:!
Action 0 Appro al n As Re uested lJ Circul e D Com nt [X) Concu rence Remarks:
0 Coordination 11 Justify lJ File D Note and Return [l For Clearance [J Per Conversation (J For Correction [ l Prepare Reply n For Your Information LJ Review n Investigation [_] See Me
_J Signature ] AD Signature
:xJ DD/DOD Signature LJ RA Signature
Date 09/11/2013
09/16/2013
09/17/2013
09/24/2013
09/24/2013
S::rnm· /l>J o nrn cumhnl .4no.nrv/Pn~t\ Rnnm No_/Bldn:_ 6SF-RA
3.1 PHYSICAL CHARACTERISTICS .............................................................................................................. 2 3.2 LAND AND RESOURCE USE ................................................................................................................. 3 3.3 HISTORY OF CONTAMINATION.............................................................................................................. 3 3.4 INITIAL RESPONSE .............................................................................................................................. 4 3.5 SUMMARY OF BASIS FOR TAKING ACTION ............................................................................................ 5
4.3.1 Source Control......................................................................................................................... 7 4.3.2 Groundwater Remediation ...................................................................................................... 8 4.3.3 Institutional Control .................................................................................................................. 9 4.3.4 Partial Deletion from the NPL .................................................................................................. 9
4.4 OPERATIONS AND MAINTENANCE ........................................................................................................ 9
5 PROGRESS SINCE LAST REVIEW ................................................................................................. 12
5.1 PROTECTIVENESS STATEMENTS FROM LAST REVIEW ......................................................................... 12 5.2 STATUS OF RECOMMENDATIONS ....................................................................................................... 13
6 FIVE-YEAR REVIEW PROCESS ...................................................................................................... 13
6.1 COMMUNITY INVOLVEMENT ............................................................................................................... 14 6.2 DOCUMENT REVIEW ......................................................................................................................... 14 6.3 DATA REVIEW .................................................................................................................................. 14
7.1 QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENTS? ................. 24 7.2 QUESTION B: ARE THE EXPOSURE ASSUMPTIONS, TOXICITY DATA, CLEANUP LEVELS, AND REMEDIAL
ACTION OBJECTIVES (RAOS) USED AT THE TIME OF THE REMEDY SELECTION STILL VALID? ........................ 25 7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO QUESTION THE
PROTECTIVENESS OF THE REMEDY? .......................................................................................................... 28
List of Figures Figure 1 Site Location Figure 2 Aerial View of Geneva Industries Superfund Site Figure 3 Geologic Cross Section A-A’ Figure 4 Geologic Cross Section B-B’ Figure 5 Profile of the Deep Monitoring Wells Figure 6 Site Map Figure 7 Treatment Plant Process Flow Diagram Figure 8 Shallow Potentiometric Map, January 7, 2009 Figure 9 Shallow Potentiometric Map, February 24, 2011 Figure 10 Shallow Potentiometric Map, April 17, 2012 Figure 11 Shallow Potentiometric Map, April 8, 2013 Figure 12 Deep Potentiometric Map, April 25 2012 Figure 13 Head Differential at the Western Edge of the Slurry Wall Figure 14 Head Differential at the Northwestern Corner of the Slurry Wall Figure 15 Head Differential at the Northeastern Corner of the Slurry Wall Figure 16 Head Differential at the Eastern Edge of the Slurry Wall Figure 17 Benzene Concentrations at MW-26 Figure 18 TCE Concentrations at MW-26 Figure 19 Vinyl Chloride Concentrations at MW-26 Figure 20 Total PCB Concentrations at MW-26 Figure 21 Vinyl Chloride Concentrations at MW-24 Figure 22 Total PCB Concentrations at MW-24 Figure 23 Total PCB Concentrations at MW-22 Figure 24 Total PCB Concentrations at MW-102 Figure 25 Total PCB Concentrations at MW-101 Figure 26 Total PCB Concentrations at MW-104 Figure 27 Identified Groundwater Wells Within 1 Mile of Geneva Figure 28 Monitoring Well MW-101 Figure 29 Monitoring Well MW-102 Figure 29 Monitoring Well MW-103 Figure 30 Monitoring Well MW-104 List of Tables Table 1 Chronology of Site Events Table 2 Identified Water Supply Wells Within 1 Mile of Geneva Table 3 Depth of Recovery and Monitoring Wells Table 4 Mann-Kendall Trend Analysis Results 2008-2013 Attachments Attachment 1 Documents Reviewed Attachment 2 Treatment Plant Effluent Sampling Results Attachment 3 Gauged Groundwater Elevations Attachment 4 Groundwater Sampling Results Attachment 5 Groundwater Well Database Search Results Attachment 6 Completed Interview Forms Attachment 7 Site Inspection Checklist Attachment 8 Site Inspection Photographs Attachment 9 Published Public Notice
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List of Acronyms ARARs Applicable or Relevant and Appropriate Requirements BTEX Benzene, Toluene, Ethylbenzene, Xylene CB&I TCEQ Site O&M Contractor CERCLA Comprehensive Environmental Response, Compensation, and Liability Act COCs Contaminants of Concern CFR Code of Federal Regulations CWM Chemical Waste Management, Inc. DNAPL Dense Nonaqueous Phase Liquid EPA Environmental Protection Agency ESD Explanation of Significant Differences GAC Granular Activated Carbon GWDB Groundwater Database GWGWING TRRP Tier 1 Residential Groundwater PCLs for Ingestion HGSD Harris-Galveston Subsidence District HHRA Human Health Risk Assessment IC Institutional Control LNAPL Light Nonaqueous Phase Liquid MCL Maximum Contaminant Level mg/L milligrams per liter msl mean sea level NCP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List O&G Oil and Grease O&M Operation and Maintenance OU Operable Unit PAH Polynuclear Aromatic Hydrocarbons PCB Polychlorinated Biphenyls PCL Protective Concentration Levels ppb parts per billion ppm parts per million RA Remedial Action RAO Remedial Action Objectives RCRA Resource Conservation and Recovery Act RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision SARA Superfund Amendments and Reauthorization Act SDWA Safe Drinking Water Act SDRDB Submitted Driller’s Reports Database SI Site Investigation TBC To Be Considered TCDD Tetrachlorodibenzodioxin TCE Trichloroethene TCEQ Texas Commission on Environmental Quality TDS Total Dissolved Solids TOC Total Organic Carbon TRRP Texas Risk Reduction Program TSCA Toxic Substances Control Act TWC Texas Water Commission TWDB Texas Water Development Board VOC Volatile Organic Compound WATEC Waste Abandonment Technologies, Inc. g/L micrograms per liter
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Executive Summary
The fourth Five-Year Review of the Geneva Industries/Fuhrmann Energy Superfund Site located in
Houston, Harris County, Texas was completed in July 2013. The results of the Five-Year Review indicate
that the remedy to date is currently protective of human health and the environment in the short term.
However, there were several issues that were identified that require further action to ensure the continued
long-term protectiveness of the remedy.
The Geneva site was a petrochemical production facility from 1967-1978. The facility produced a variety
of organic compounds including polychlorinated biphenyls (PCBs). After the site closed, the U.S.
Environmental Protection Agency (EPA) originally organized the work for this site into two Operable Units
(OUs): soil (OU-1) and groundwater (OU-2). The Record of Decision (ROD) for the site was signed
September 18, 1986. An Explanation of Significant Difference (ESD) was issued for the site in 1993 and
2007.
A cutoff slurry wall that surrounds the perimeter of the site is in place to help prevent migration of affected
groundwater from inside the wall, with inward gradients across the wall maintained by a groundwater
extraction system. The operations and maintenance (O&M) of the site is ongoing; O&M activities include
pumping of affected groundwater, treatment and discharge onsite of the extracted groundwater,
performance and compliance monitoring to ensure the remedial action continues to perform as planned,
and maintenance of the cap, slurry wall, and onsite groundwater treatment plant.
The pump and treat system appears to be maintaining an inward gradient to the site most of the time, as
intended, and the system is currently controlling the horizontal migration of contaminated groundwater in
the 30-foot sand unit. Groundwater monitoring over the past five years shows that PCB contaminated
groundwater has migrated from the 30-foot sand unit to the lower 100-foot sand unit, and PCB has been
detected in the aquifer units below the 100-foot sand. There currently is no remediation or containment of
the contaminated groundwater in the 100-foot sand unit, and if no action is taken it is expected that off
site and vertical migration of contaminated groundwater will increase.
The remedy for the OU-1 (soil) at the Geneva site is protective of human health and the environment
because the waste has been removed or contained and is protected from erosion. The remedy for the
OU-2 (groundwater) is protective of human health and the environment in the short term because there is
no evidence that there is current exposure. In order to remain protective for the long term, the following
recommendations should be implemented:
1. An investigation of the possible mechanisms for PCB entering the deeper water bearing units
should be conducted with the goal of mitigating the downward migration of PCB from the 30-foot
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sand unit. The investigation should include the possibility that the deep monitoring wells are the
source of the downward migration of PCB.
2. The ROD should be amended with an ESD or ROD amendment to include a cleanup criteria for
PCB in groundwater.
3. Recovery and treatment of PCB contaminated groundwater in the 100-foot sand unit should be
conducted to prevent the further migration of PCB.
4. The capacity of the treatment plant needs to be increased. An optimization study should be
conducted to determine the best method of increasing the plant capacity.
5. There has been sporadic operation of the recovery/treatment system and groundwater elevation
gauging during the review period. The recovery/treatment system needs to be operated on a
consistent basis to maintain an inward gradient of the contaminated 30-foot sand unit within the
slurry wall to prevent migration of contaminants off site. Groundwater elevation gauging is
needed at least quarterly as recommended in the last five-year review to confirm the inward
gradient is being maintained.
6. Verify that no groundwater use is occurring in the 100-foot sand unit in the area of MW-24. If PCB
concentrations continue to exceed the MCL at MW-24, consideration should be given to installing
additional groundwater monitoring wells downgradient of MW-24.
7. Implement ICs as mandated in the 2007 ESD.
8. A vapor intrusion screen should be performed on the site treatment system building.
9. An evaluation of the potential for contaminated groundwater from the site to discharge to the
Harris County flood control channel should be conducted. If there is a potential for this to occur,
sampling and analysis of the channel sediments and surface water for site contaminants should
be conducted to verify the sediments and surface water are protective of human health and the
environment.
10. An evaluation should be made of the groundwater flow direction in the 100-foot sand unit, and a
determination made as to the sufficiency of the number and location of monitoring wells along the
northern boundary of the site.
11. Monitoring wells should be locked, and missing well caps and bollards should be replaced.
12. A review of past monitoring wells used at the site should be conducted and wells that are no
longer needed should be identified, located, and properly plugged and abandoned.
13. An O&M log should be maintained for the site.
14. Soil erosion under well RW-03 well pad should be repaired.
15. Brackets holding the conduits on the stands east of the deep monitoring wells should be repaired
to hold the conduits on the stands.
16. The fire ant mounds on the cap should be mitigated.
17. All site decision documents and past five-year reviews should be available for public review at the
M.D. Anderson Library.
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18. Copies of the sampling analytical reports should be retained to provide verification that discharge
criteria are being met.
19. Erosion control fabric exposed at the surface at the toe of the southeast corner of the cap should
be covered with soil and grass.
20. The bent grate covering the floor drainage in the treatment plant should be replaced or repaired.
21. The depths of the deep monitoring wells MW-101, -102, -103 and -104 should be gauged to verify
the currently reported depths are correct.
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Five-Year Review Summary Form
SITE IDENTIFICATION
Site Name: Geneva Industries/Fuhrmann Energy Superfund Site
EPA ID: TXD980748453
Region: 6 State: TX City/County: Houston/Harris County
SITE STATUS
NPL Status: Final
Multiple OUs? Yes
Has the site achieved construction completion?
Yes
REVIEW STATUS
Lead agency: EPA If “Other Federal Agency” was selected above, enter Agency name: Click here to enter text.
Author name (Federal or State Project Manager): EPA Region 6, with support from USACE Tulsa District
Author affiliation: EPA Region 6
Review period: May 2013 – July 2013
Date of site inspection: June 25, 2013
Type of review: Statutory
Review number: 4
Triggering action date: September 25, 2008
Due date (five years after triggering action date): September 25, 2013
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Five-Year Review Summary Form (continued)
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the Five-Year Review:
1
Issues and Recommendations Identified in the Five-Year Review:
OU(s): 2 Issue Category: Changed Site Conditions
Issue: PCB concentrations exceed the MCL and are increasing in the 100-foot sand unit.
Recommendation: An investigation of the possible mechanisms for PCB entering the deeper water bearing units should be conducted with the goal of mitigating the downward migration of PCB from the 30-foot sand unit. The investigation should include the possibility that the deep monitoring wells are the source of the downward migration of PCB.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No Yes TCEQ EPA September 2015
OU(s): 2 Issue Category: Changed Site Conditions
Issue: No cleanup criteria has been established for PCB in the groundwater in the ROD.
Recommendation: The ROD should be amended with an ESD or ROD amendment to include a cleanup criteria for PCB in groundwater.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No Yes EPA EPA September 2018
OU(s): 2 Issue Category: Changed Site Conditions
Issue: There is no remediation or containment of the PCB contaminated groundwater in the 100-foot sand unit.
Recommendation: Recovery and treatment of PCB contaminated groundwater in the 100-foot sand unit should be conducted to prevent the further migration of PCB.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
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No Yes TCEQ EPA September 2015
OU(s): 2 Issue Category: Operations and Maintenance
Issue: There is insufficient treatment plant capacity to treat pumped groundwater from both the 30-foot sand and 100-foot sand units.
Recommendation: The capacity of the treatment plant needs to be increased. An optimization study should be conducted to determine the best method of increasing the plant capacity.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No Yes TCEQ EPA September 2015
OU(s): 2 Issue Category: Operations and Maintenance
Issue: There has been sporadic operation of the recovery/treatment system and groundwater elevation gauging during the review period.
Recommendation: The recovery/treatment system needs to be operated on a consistent basis to maintain an inward gradient of the contaminated 30-foot sand unit within the slurry wall to prevent migration of contaminants off site. Groundwater elevation gauging is needed at least quarterly as recommended in the last five-year review to confirm the inward gradient is being maintained.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No Yes TCEQ EPA March 2014
OU(s): 2 Issue Category: Changed Site Conditions
Issue: PCB concentrations appear to be increasing in MW-24 at the eastern boundary of the site in the 100-foot sand unit and PCB contaminated groundwater may be leaving the site boundaries at levels exceeding the MCL.
Recommendation: Verify that no groundwater use is occurring in the 100-food sand unit in the area of MW-24. If PCB concentrations continue to exceed the MCL at MW-24, consideration should given to installing additional groundwater monitoring wells downgradient of MW-24.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No Yes TCEQ EPA ASAP
OU(s): 2 Issue Category: Institutional Controls
Issue: Institutional controls mandated in the 2007 ESD have not been implemented at the site.
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Recommendation: Implement ICs as mandated in the 2007 ESD.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No Yes TCEQ EPA September 2015
OU(s): 2 Issue Category: Monitoring
Issue: Groundwater contained within the slurry wall in the 30-foot sand is contaminated with volatile organic compounds BTEX and TCE. The treatment system building is adjacent to the slurry wall on site and there is a possibility of vapor intrusion in the building at levels above those protective of human health.
Recommendation: A vapor intrusion screen should be performed on the site treatment system building.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No Yes TCEQ EPA March 2014
OU(s): 2 Issue Category: Monitoring
Issue: Due to the shallow depth to groundwater of the 30-foot sand unit along the eastern boundary of the site and the detected contaminants in MW-26, there is a possibility that contaminated groundwater from the 30-foot sand unit has discharged into the Harris County flood control channel.
Recommendation: An evaluation of the potential for contaminated groundwater from the site to discharge to the Harris County flood control channel should be conducted. If there is a potential for this to occur, sampling and analysis of the channel sediments and surface water for site contaminants should be conducted to verify the sediments and surface water are protective of human health and the environment.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No Yes TCEQ EPA March 2014
OU(s): 2 Issue Category: Monitoring
Issue: Based on the current information showing the groundwater flow direction in the 100-foot sand unit is to the north, there may be insufficient groundwater monitoring along the northern boundary of the site.
Recommendation: An evaluation should be made of the groundwater flow direction in the 100-foot sand unit, and a determination made as to the sufficiency of the number and location of monitoring wells along the northern boundary of the site.
Affect Current Affect Future Implementing Oversight Milestone
xvii
Protectiveness Protectiveness Party Party Date
No Yes TCEQ EPA September 2015
OU(s): 2 Issue Category: Operations and Maintenance
Issue: None of the monitoring wells have locks on the casing covers. The old recovery wells (RW-01 through RW-05 and RW-7 through RW-10) now used as piezometers do not have caps. Monitoring wells MW-02, MW-23 and MW-25 are missing bollards.
Recommendation: Monitoring wells should be locked, and missing well caps and bollards should be replaced.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No No TCEQ EPA September 2014
OU(s): 2 Issue Category: Operations and Maintenance
Issue: Two monitoring wells, MW-18 and MW-02, were identified during the site inspection as being lost or abandoned.
Recommendation: A review of past monitoring wells used at the site should be conducted and wells that are no longer needed should be identified, located, and properly plugged and abandoned.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No No TCEQ EPA September 2018
OU(s): 2 Issue Category: Operations and Maintenance
Issue: No O&M log was found during the site inspection.
Recommendation: An O&M log should be maintained for the site.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No No TCEQ EPA ASAP
OU(s): 2 Issue Category: Operations and Maintenance
Issue: The soil has eroded out from beneath the well pad at RW-03.
Recommendation: Soil erosion under well RW-03 well pad should be repaired.
Affect Current Affect Future Implementing Oversight Milestone
xviii
Protectiveness Protectiveness Party Party Date
No No TCEQ EPA March 2014
OU(s): 2 Issue Category: Operations and Maintenance
Issue: East of the deep monitoring wells, brackets holding the conduits on the stands have failed.
Recommendation: Brackets holding the conduits on the stands east of the deep monitoring wells should be repaired to hold the conduits on the stands.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No No TCEQ EPA March 2014
OU(s): 2 Issue Category: Operations and Maintenance
Issue: Fire ant mounds were observed on the cap which could create a conduit between the ground surface and the buried wastes.
Recommendation: The fire ant mounds on the cap should be mitigated.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No No TCEQ EPA Continuous
OU(s): 2 Issue Category: Operations and Maintenance
Issue: Site documents are missing from the local site information repository, the M.D. Anderson Library on the main campus of the University of Houston.
Recommendation: All site decision documents and past five-year reviews should be available for public review at the M.D. Anderson Library.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No No TCEQ EPA March 2014
OU(s): 2 Issue Category: Monitoring
Issue: The March 31, 2009 sample from the CWST exceeded the PCB discharge criteria. The water was resampled on April 30, 2009 and was reported to meet the discharge criteria. This review was unable to confirm that the resampled results met the discharge criteria because the analytical results were not provided.
Recommendation: Copies of the sampling analytical reports should be retained to provide verification that discharge criteria are being met.
xix
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No No TCEQ EPA Continuous
OU(s): 2 Issue Category: Operations and Maintenance
Issue: There is erosion control fabric exposed at the surface at the toe of the cap at the southeast corner.
Recommendation: Erosion control fabric exposed at the surface at the toe of the southeast corner of the cap should be covered with soil and grass.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No No TCEQ EPA September 2015
OU(s): 2 Issue Category: Operations and Maintenance
Issue: The grate covering the floor drainage channel in the treatment plant is bent and presents a tripping hazard.
Recommendation: The bent grate covering the floor drainage in the treatment plant should be replaced or repaired.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No No TCEQ EPA September 2015
OU(s): 2 Issue Category: Monitoring
Issue: Currently reported well depths given for MW-101 and MW-102 do not match the depths given in the original 1985 well schematics, and it appears the labels for these two wells have been switched at some point in the past. The labels for the other two deep wells MW-103 and MW-104 may have been switched also.
Recommendation: The depths of the deep monitoring wells MW-101, -102, -103 and -104 should be gauged to verify the currently reported depths are correct.
Affect Current Protectiveness
Affect Future Protectiveness
Implementing Party
Oversight Party
Milestone Date
No No TCEQ EPA September 2015
xx
Protectiveness Statement(s)
Include each individual OU protectiveness determination and statement. If you need to add more protectiveness determinations and statements for additional OUs, copy and paste the table below as many times as necessary to complete for each OU evaluated in the FYR report.
Operable Unit: 1
Protectiveness Determination: Protective
Addendum Due Date (if applicable): Click here to enter date.
Protectiveness Statement: The remedy for OU-1 concerning contaminated soil at the Geneva site is protective of human health and the environment because the waste has been removed or contained and is protected from erosion.
Addendum Due Date (if applicable): Click here to enter date.
Protectiveness Statement: The remedy for OU-2 concerning contaminated groundwater is protective of human health and the environment in the short term because there is no evidence that there is current exposure. Twenty-one issues were identified which need to be addressed for the remedy to remain protective for the long term, and the recommendations and follow-up actions listed in Section 9 should be implemented to address these issues. In addition to the recommendations in Section 9, site operations and implementation of performance and compliance monitoring should continue.
Sitewide Protectiveness Statement (if applicable)
For sites that have achieved construction completion, enter a sitewide protectiveness determination and statement.
Addendum Due Date (if applicable): Click here to enter date.
Protectiveness Statement: Because the completed remedial actions and monitoring program for the Geneva site are protective for the short term, the remedy for the site is protective of human health and the environment and will continue to be protective if the action items identified in this report are addressed.
1
1 Introduction
The purpose of a Five Year Review is to determine how well an existing remedial action is operating in
order to protect human health and the environment, and to identify any problems or concerns that are
affecting or may in the future affect the protectiveness of the remedy. The Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), 42 United States Code § 9601 et seq., and the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 50 Code of Federal
Regulations (CFR) Part 300, call for Five-Year Reviews of certain remedial actions. EPA policy also calls
for a Five-Year Review of remedial actions in some other cases. The statutory requirement to conduct a
Five-Year Review was added to CERCLA as part of the Superfund Amendments and Reauthorization Act
(SARA) of 1986. EPA classifies each Five-Year Review as either statutory or policy depending on
whether it is being required by statute or is being conducted as a matter of policy. The Five-Year Review
for the Geneva site is required by statute.
As specified by CERCLA and the NCP, statutory reviews are required for sites where, after remedial
actions are complete, hazardous substances, pollutants, or contaminants will remain onsite at levels that
will not allow for unlimited use or unrestricted exposure. Statutory reviews are required for such sites if
the Record of Decision (ROD) was signed on or after the effective date of SARA. CERCLA §121(c), as
amended by SARA, states:
If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented.
Under the NCP, the Code of Federal Regulations (CFR) states, in 40 CFR §300.430(f)(4)(ii):
If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.
The Geneva Industries/Fuhrmann Energy Superfund Site is organized into two Operable Units (OUs):
one for soil (OU-1) and one for groundwater (OU-2). The ROD was signed in September 1986. The
Five-Year Review for the Geneva site is required by statute because materials remain onsite above levels
that allow for unlimited use and unrestricted exposure. Because the Geneva site is a Superfund site,
EPA has regulatory authority. The triggering action for this review is five years from the last Five-Year
Review. The last Five-Year Review was signed on September 25, 2008. This is the fourth Five-Year
Review for the Geneva site and was conducted during the period of May 2013 through July 2013.
2
2 Site Chronology A chronology of events and dates is included in Table 1, provided at the end of the report.
3 Background This section describes the physical setting of the site, a description of the land and resource use, and the
environmental setting. This section also describes the history of contamination associated with the site,
the initial response actions taken, and the basis for each action.
3.1 Physical Characteristics
The Geneva site is approximately 13.5 acres and is located at 9334 Canniff Road in Houston, Texas.
The site is less than 1 mile east of Interstate Highway 45 and approximately 2 miles east of Houston
Hobby Airport. Approximately 15,500 people live within one mile of the site and some residences are
located less than 50 feet from the site boundary. The site and surrounding area are flat and have a
maximum surface elevation of approximately 35 feet above mean sea level (msl). The site is drained by
the Harris County Flood Control District Channel, which runs along the eastern boundary of the site. The
channel flows in a northerly direction into Berry Bayou (EPA, 1986). Figure 1 shows the location of the
site. Figure 2 shows an aerial view of the site.
Two geologic cross-sections presented in the Preliminary Groundwater Remediation Assessment
(Corrigan, 1998) are presented as Figures 3 and 4 in this review. Figure 3 presents an east-west
section across the center of the site. Figure 4 presents a north-south section along the eastern boundary
of the site. Based on the cross-sections, site stratigraphy consists of remediation construction fill material
ranging in thickness from 10 to 20 feet and covered by a clay cap. Underlying the fill material, there are
five to 10 feet of clays and sandy, silty clays which comprise the uppermost aquitard at the site and pre-
remediation surficial soils (Horizon 1). Below Horizon 1 is the uppermost or "30-foot sand" aquifer which
consists of clayey, silty, very fine-grained sand and ranges in thickness from 12 to 25 feet (Horizon 2).
Underlying the 30-foot sand is a clay aquitard (Horizon 3) which separates the 30-foot sand from the
deeper "100-foot sand" aquifer. The aquitard clay ranges in thickness from 12 to 25 feet. Horizon 4, the
100-foot Sand consists of 50 to 55 feet of coarse sand with interbedded pebbly gravels. Locally, the
upper portion of this aquifer contains interbedded clays and silts as a transition zone to the overlying
aquitard clay. Underlying the 100-foot sand aquifer is another clay aquitard (Horizon 5) at a nominal
depth of 70 to 80 feet below msl or approximately 105 to 100 feet below ground surface (Corrigan, 1998).
3
The groundwater-bearing units below the site are the 30-foot sand unit and the 100-foot sand unit, which
are both part of the upper Chicot Aquifer. The upper unit of the Chicot Aquifer is a minor water supply
aquifer. Figure 5 shows a profile of the sand units and the deep monitoring wells installed in the center of
the site.
Corrigan stated (Corrigan, 1998) that information presented in the 1986 Site Investigation (SI) (IT, 1986)
indicated the regional groundwater gradient in the 30-foot sand aquifer outside the slurry wall is 1.9 x 10-3
ft/ft to the east-northeast, and that based on the October 1998 groundwater gauging event, the
approximate gradient and flow direction for groundwater in the 30-foot sand outside the slurry wall is
0.001 ft/ft to the east-northeast.
At the time of the ROD, the gradient in the 100-foot sand unit was believed to be to the west and
southwest. Corrigan stated that based on groundwater levels measured in the October 1998 monitoring
event, the gradient in the 100-foot sand aquifer is 0.01 ft/ft to the north-northeast, but that based on
historical data, the groundwater flow direction in the 100-foot sand aquifer may also trend from west to
southwest (Corrigan, 1998). Recent gauging of groundwater in the 100-foot sand indicates the flow
direction is to the north (Figure 12).
3.2 Land and Resource Use
The primary land uses near the site are industrial and residential. The lot immediately west of the site
has changed from industrial use to residential use since the last five-year review. A search of available
databases and past records for the site found 15 potential water supply wells within one mile of the site.
Of the 15 wells, the closest well is a domestic well located approximately 1000 feet south of the slurry wall
boundary, reported to be 100 feet deep. All of other identified water supply wells are 2800 feet or greater
from the site and are too distant from the site to be affected by the site contaminants. The City of South
Houston operates public water supply wells approximately 3000 feet east northeast from the site, with
depths ranging from 780 to 1200 feet deep. Section 6.3.4 describes in more detail the water wells near
the Geneva site. A summary of the 15 water wells is given in Table 2.
3.3 History of Contamination
Prior to 1967, the Geneva site was used for petroleum exploration and production. Between 1967 and
1978, Geneva Industries operated a petrochemical production facility at the site. The facility produced a
variety of organic compounds, including biphenyl, polychlorinated biphenyls (PCBs), phenyl phenol,
naptha, and No. 2 and 6 fuel oils. Geneva Industries began production of PCBs in June 1972 before
declaring bankruptcy in November 1973. Pilot Industries operated the facility from February 1974 to
December 1976. Intercoastal Refining owned the facility from December 1976 to December 1980;
4
however, the facility ceased operation in September 1978. Facility operations never resumed. Lonestar
Fuel Co. owned the property from December 1980 to May 1982. Fuhrmann Energy purchased the site in
1982. The Texas Commission on Environmental Quality (TCEQ) is attempting to determine the current
ownership as part of the process of implementing institutional controls on the site.
As of 1981, the site and adjoining property to the south contained processing tanks and piping, a large
wastewater lagoon, two smaller lagoons, a closed lagoon holding solid PCB-containing wastes, a diked
tank area, several drum storage areas, a landfill, and a possible landfarm. As a result of past practices at
the site, extensive soil and shallow groundwater contamination existed at the site.
3.4 Initial Response
A preliminary site investigation conducted by EPA revealed PCB concentrations of up to 9,000 parts per
million (ppm) in soil at the site and up to 104 ppm in sediment in the adjacent flood control channel.
PCBs and other organic compounds were also detected in groundwater samples collected from on-site
groundwater monitoring wells. Based on the results of the investigation, the site was scored using the
Hazard Ranking System and was proposed for inclusion to the National Priorities List (NPL) in September
1983. The site was placed on the NPL in September 1984.
A Planned Removal was performed by EPA from October 1983 to February 1984 to close out all three
lagoons, remove all drummed waste on the surface, remove all off-property soils containing greater than
50 ppm PCBs, install a cap over all on-property soils containing greater than 50 ppm PCBs, and improve
site drainage. Approximately 3,400 cubic yards of contaminated soil and sludge, 550 drums of waste,
and 30 tons of asbestos were removed and transported to an approved facility in Emmelle, Alabama.
Other removal actions to plug abandoned wells and remove storage tank materials were performed in
May and September 1984, respectively. The total cost of the removal actions performed was $1,748,179.
Fuhrmann Energy salvaged equipment from the site in 1984 and 1985.
A Remedial Investigation/Feasibility Study (RI/FS) was performed from September 1984 to December
1985. Soil borings and monitoring wells were installed on and off site during the RI. At the Geneva site,
the Remedial Investigation reports were titled Site Investigation, and the references to RI and SI in this
review are to referring to the 1985 and 1986 Site Investigation reports.
On September 18, 1986, the ROD was signed for the Geneva site. The ROD called for source control
and groundwater remediation, and is further discussed in Sections 4.3.1 and 4.3.2. In July 1993 EPA
issued an Explanation of Significant Differences (ESD) that raised the remedial goal for trichloroethylene
(TCE) from 1.0 g/L to 5.0 g/L. In May 2007, an ESD was published that included institutional controls
as part of the remedy.
5
3.5 Summary of Basis for Taking Action
Based on the data collected during the RI, it was determined that actual or threatened releases of
hazardous substances from the Geneva site, if not addressed by implementing the remedy selected in
the ROD, could present an imminent and substantial endangerment to public health, welfare, or the
environment.
4 Remedial Actions This section provides a description of the remedial action objectives (RAO), selection, and
implementation. It also describes the ongoing O&M, and the overall progress made at the Geneva site.
As previously described, the site was initially divided into two OUs; soil (OU-1) and groundwater (OU-2).
4.1 Remedial Action Objectives
EPA signed the ROD for the Geneva site on September 18, 1986. Specific remedial objectives were
developed to aid in the development and screening of remedial action (RA) alternatives for the site. The
remedial objectives for the Geneva site are listed below:
Prevent future contamination of the adjacent flood control channel.
Minimize direct contact with contaminated soil on-site.
Prevent degradation of off-site soil.
Prevent further degradation of off-site groundwater in the 30-foot sand unit and reduce the risk of
degradation of deeper sand units.
Reduce contamination in the 100-foot sand unit.
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.
The following criteria were selected for each migration pathway at the Geneva site:
Pathway Criteria
Offsite soil PCB < 25 ppm in the industrial area PCB < 10 ppm in the residential area
Monitoring well MW-26 is located along the eastern boundary of the site outside the slurry wall in the 30-
foot sand unit, and has had exceedances of the MCL for benzene, TCE, vinyl chloride and total PCB over
the last five years. A Harris County flood control channel runs along the eastern boundary of the site,
about 40 feet east of MW-26. Gauged depth to groundwater in the 30-foot sand unit in MW-26 has
ranged from 7.39 to 10.81 feet during 2005 to 2013. Due to the shallow depth to groundwater of the 30-
foot sand unit in this area and the detected contaminants at MW-26, there is a possibility that
contaminated groundwater from the 30-foot sand unit has discharged into the channel. An evaluation of
the potential for contaminated groundwater from the site to discharge to the flood control channel should
be conducted. If there is a potential for this to occur, sampling and analysis of the channel sediments and
surface water for site contaminants should be conducted to verify the sediments and surface water are
protective of human health and the environment.
Based on the current information showing the groundwater flow direction in the 100-foot sand unit is to
the north, there may be insufficient groundwater monitoring along the northern boundary of the site. An
evaluation should be made of the groundwater flow direction in the 100-foot sand unit, and a
21
determination made as to the sufficiency of the number and location of monitoring wells along the
northern boundary of the site.
A review of available information on water wells within one mile of the Geneva site indicates there is no
known use of contaminated groundwater near the site. However, because groundwater with PCB levels
above the MCL is migrating off site along the eastern boundary in the 100-foot sand unit, there should be
a confirmation that groundwater is not being used in this area. As the site is currently being operated
there is no remediation or containment occurring in the 100-foot sand unit and it is expected that PCB
contaminated groundwater will continue to migrate off site.
6.4 Interviews
An interview was conducted with the site O&M manager Russell Perry during the site visit conducted on
June 25, 2013 and a completed interview form was submitted in July via email by Mr. Perry. Gary Miller
of EPA and Phillip Winsor of TCEQ submitted interview forms in June 2013 via e-mail. An interview form
was submitted to Ceil Price, City of Houston Senior Assistant City Attorney by email, which also included
an invitation to anyone in the Houston community to participate in a review interview. The completed
interview record forms are presented in Attachment 6.
Gary Miller is the EPA Remediation Project Manager for the site. Mr. Miller stated that past shutdowns of
the pumping system and water treatment plant may not have maintained an inward gradient across the
slurry wall surrounding the contaminated area at the site. Mr. Miller also recommended a review of the
treatment plant operations to optimize performance and reduce downtime.
Phillip Winsor is the TCEQ Project Manager for the site. Mr. Winsor stated that work conducted at the site
has been good, and that ten recovery wells for the pump and treat system were replaced in 2011 as the
original wells had problems with sanding up. The site has had one incident with a facility break in;
however, apparently no items were taken. Mr. Winsor noted that samples in the deeper wells have
detected contaminants, but that there had been no dedicated pumps available for the deeper wells. A
dedicated pump is currently being installed in the deeper well. Mr. Winsor also noted that surface
facilities are in need of repair or replacement in order to keep up with the needed flow to maintain an
inward gradient, and that funding is a major constraint. Mr. Winsor recommends an optimization review
for the current treatment system’s capability to treat the required volume for gradient maintenance.
Russell Perry is the site manager for TCEQ O&M contractor CB&I. Mr. Perry has been manager of the
site for a number of years and provided an excellent review of site conditions and problems in the
interview form included in Attachment 6. The bullets below are a summary of the major points of the
interview.
22
New recovery wells have been installed at the site since 2008. The former recovery wells
produced abundant fine silt that was a continual maintenance issue for the treatment system.
After the new recovery wells were installed, the system operation improved significantly, and
greatly reduced the silt/sludge production issues.
The objective of groundwater removal at the site is to maintain a lower groundwater level inside
the slurry wall surrounding the containment cell, than the groundwater level outside the slurry
wall, which is an engineering control to prevent contaminant migration. The remedial objective
(inside the slurry wall) is NOT restoration of the shallow aquifer through removal of DNAPL and/or
groundwater.
Since 2008 there have been exceedances in monitoring well groundwater samples of TCEQ
Texas Risk Reduction Program (TRRP) Tier 1 Protective Concentration Levels (PCLs) for
Residential Groundwater Ingestion (GWGWIng) for benzene, TCE and total PCBs. Although the
1986 ROD does not specify the TRRP regulations as an ARAR, the TRRP regulations were
adopted for this project as agreed upon by the contractor and TCEQ, and specified in the
Sampling and Analysis Plan.
The pump in recovery well RW-6 was replaced in 2012, but has not been activated to date, due to
the larger volumes of water anticipated to be required for aquifer control by pumping, and the
limited holding capacity of the clean water storage tanks. Some work has been performed to
obtain a continuous discharge permit for disposal of treated water potentially generated by RW-6,
to increase the current discharge allowed by batch treatment (generated by pumping the shallow
zone wells).
Total PCBs have been detected at concentrations exceeding TRRP Tier 1 PCLs in deep monitor
wells MW-101, MW-102, and MW-104 (deep monitor wells with depths of 292 feet, 112 feet, and
852 feet, respectively). The migration pathway of total PCBs from the source area to the deep
monitor wells has not been determined. Plans are underway to install permanent pumps in
monitor wells MW-102 and MW-104 such that representative water samples may be collected
and pump tests may be performed to evaluate aquifer response (if any) to all closely-spaced
clustered monitor wells, including MW-101, MW-102, MW-103, and MW-104.
The extent of impact to groundwater through evaluation of groundwater samples taken from the
deep monitor wells (MW-101 through MW-104) is not fully understood at this time. Additional
investigation, including pumping tests of the deep monitor wells, plugging of the deep monitor
wells (if needed), and installation of additional deep monitor wells (outside the source area) may
be a consideration. Sampling of nearby residential and municipal water wells completed in the
same aquifers as the monitor wells (if any) may also be a consideration.
23
6.5 Site Inspection
An inspection was conducted at the site on June 25, 2013. The completed site inspection checklist is
provided in Attachment 7. Site inspection tasks included a visual inspection of site features including the
water treatment facility, the cap, monitoring wells, fences and gates. The inspection was conducted by
John Hickman and Wendy Lanier of the U.S. Army Corps of Engineers. They were accompanied by Gary
Miller (EPA), Terry Andrews (TCEQ), Audrey Smith (TCEQ), and Russell Perry (CB&I, Geneva site
manager). Photographs taken during the Geneva site inspection are provided in Attachment 8.
The site is in good condition overall. The soil cap is grass covered and kept mowed. There is erosion
control fabric exposed at the surface at the toe of the cap at the southeast corner which should be
covered with soil and grass. None of the monitoring wells have locks on the casing covers. These wells
should be locked. Even though these wells are located within a fenced area the site is not occupied more
than one day a month and there is evidence the site could possibly have been used for unauthorized
recreational activities. The remains of a soccer ball were found on the cap during the site inspection
indicating the cap could possibility have been used for recreation. Bollards were observed to be missing
at MW-23 and MW-25, and should be replaced. New recovery wells RW-01R through RW-05R and RW-
7R through RW-10R were installed in February 2011 adjacent to the old recovery wells, and the old
recovery wells now function as piezometers. None of the old recovery wells have caps, and caps should
be installed on these wells to protect the saturated zones from direct exposure. The soil has eroded out
from beneath the well pad at RW-03, which should be repaired. MW-02 was observed east of the clean
water storage tanks on the outside of the fence line. The well had no bollards, no lock on the casing
cover, the cover was rusted shut, and the well appeared to be abandoned. MW-18 which appears east of
the Geneva site on past site maps was reported by site manager Russell Perry to be lost. The 1986 ROD
specifies that “the existing monitoring wells and piezometers that are not included in the 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 30-foot or 100-foot sands."
A review of the past site monitoring wells should be conducted and monitoring wells that are no longer
needed should be identified, located, and properly plugged and abandoned. On-site documents were
reviewed, and no O&M log was found. An O&M log should be maintained for the site. East of the deep
monitoring wells, brackets holding the conduits on the stands had failed, and the brackets should be
repaired to hold the conduits on the stands. Fire ant mounds were observed on the cap. The second
five-year review identified fire ants on the cap as an issue due to the possibility of fire ant burrows
creating a conduit between the ground surface and the buried wastes. As recommended in the previous
review, the fire ant mounds on the cap should be mitigated. No significant problems were observed in the
treatment plant. The grate covering the floor drainage in the plant was damaged and should be replaced
or repaired.
24
The local site information repository, M.D. Anderson Library on the main campus of the University of
Houston, was visited to verify that site documents are available to the public. The only site decision
document found was the 2007 ESD, and none of the RI/FS, ROD nor past five-year review documents
were found. All site decision documents and past five-year reviews should be available for public review
at the M.D. Anderson Library or publicly available official repository.
7 Technical Assessment The Five-Year Review must determine whether the remedy at a site is protective of human health and the
environment. The EPA guidance describes three questions used to provide a framework for organizing
and evaluating data and information, and to ensure all relevant issues are considered when determining
the protectiveness of a remedy.
7.1 Question A: Is the Remedy Functioning as Intended by the Decision Documents?
No, the remedy is not functioning completely as intended by the decision documents. Although the
remedy is not functioning as intended by the decision documents, the issues identified do not affect the
current protectiveness, and the remedy is protective in the short-term. The ROD specified treatment of
the 30-foot and 100-foot sand units to reduce TCE concentrations. While pumping and treatment of the
100-foot sand unit was part of past remedial operations at the site, this ceased due to concerns that
pumping from the 100-foot sand unit could possible draw more highly contaminated groundwater from the
30-foot sand unit into the lower unit. There currently is no pumping and treatment of the 100-foot sand
unit. Total PCB concentrations exceed the MCL and are increasing in the 100-foot sand unit. The ROD
established cleanup criteria for TCE in groundwater; however, no cleanup criteria was established for
PCB.
Groundwater Remediation. Groundwater monitoring during the review period indicates PCB levels are
above the MCL in the 100-foot sand unit and increasing, and that PCB is migrating off site in the 100-
sand unit. PCBs have also been detected above the MCL in the water bearing units below the 100-foot
sand. An investigation of the possible mechanisms for PCB entering the deeper water bearing units
should be conducted with the goal of mitigating the downward migration of PCB from the 30-foot sand
unit.
The ROD did not establish cleanup criteria for PCB in groundwater. Since the time of the ROD, PCB has
migrated from the 30-foot sand unit contained within the slurry wall to the uncontained 100-foot sand unit
to levels exceeding the MCL. To allow the appropriate remediation and prevention of further migration of
25
PCB in the 100-foot sand unit, the ROD should be amended with an ESD or ROD amendment to include
a cleanup criteria for PCB in groundwater.
Because the treatment plant has insufficient capacity to treat groundwater pumped from both the 30-foot
sand and 100-foot sand-unit, there is currently no pumping of the 100-foot sand unit. There is no
remediation or containment occurring in the 100-foot sand unit and it is expected that PCB contaminated
groundwater will continue to migrate off site under these conditions. The capacity of the treatment plant
needs to be increased, and an analysis should be conducted to determine the optimal method of
increasing the capacity. Recovery and treatment of PCB contaminated groundwater in the 100-foot sand
unit should be conducted to prevent the further migration of PCB.
There has been sporadic operation of the recovery/treatment system and groundwater elevation gauging
during the review period. The recovery/treatment system needs to be operated on a consistent basis to
maintain an inward gradient into the slurry wall contained contaminated 30-foot sand unit to prevent
migration of contaminants off site. Groundwater elevation gauging is needed at least quarterly as
recommended in the last five-year review to confirm the inward gradient is being maintained.
A review of available information on water supply wells within one mile of the Geneva site indicates there
is no known use of contaminated groundwater near the site. However, because groundwater with PCB
levels above the MCL is migrating off site along the eastern boundary in the 100-foot sand unit, it should
be confirmed that groundwater is not being used in this area.
Implementation of Institutional Controls. The May 2007 ESD mandated institutional controls as part of the
remedy. No institutional controls are currently established for the site. Institutional controls should be
implemented to prohibit use of groundwater and to maintain cap integrity.
7.2 Question B: Are the Exposure Assumptions, Toxicity Data, Cleanup Levels, and Remedial Action Objectives (RAOs) Used at the Time of the Remedy Selection Still Valid?
No, some of the information used at the time of the remedy is no longer valid. No changes have occurred
which affect the current protectiveness of the remedy; however, two changes in the exposure
assumptions have been identified which require additional investigation to maintain protectiveness in the
long term. The purpose of this question is to evaluate the effects of any significant changes in standards
or assumptions used at the time of remedy selection. Changes in promulgated standards or “to be
considered” (TBC) and assumptions used in the original definition of the remedial action may indicate that
an adjustment in the remedy is necessary to ensure the protectiveness of the remedy.
26
Changes in ARARs.
Applicable or Relevant and Appropriate Requirements (ARARs) for this site were identified in the ROD
dated September 1986 and the July 1993 ESD. The five-year review for this site included identification of
and evaluation of changes in the ROD-specified ARARs to determine whether such changes may affect
the protectiveness of the selected remedy. A comprehensive list of ARARs identified in the ROD is
provided below.
The ARARs identified by the ROD are divided into chemical-specific, action-specific, and location-specific
categories. Some of these ARARs apply to activities that are not currently taking place at the site or
conditions that do not currently exist. Therefore, as a practical matter, they are no longer applicable to
site remediation. However, should additional construction activities occur, these ARARs may be
applicable.
Chemical-Specific ARARs:
Chemical specific ARARs are usually health or risk based numerical values or methodologies that, when
applied to site-specific conditions, result in the establishment of numerical values. These values establish
the acceptable amount or concentration of a chemical that may be found in, or discharged to, the
environment. The chemical-specific ARARs associated with the selected remedy are:
Toxic Substances Control Act (TSCA)(40 CFR Part 761) - establishes disposal requirements for
PCB-contaminated materials, technical standards for landfills and incinerators
At the time of the ROD, the TSCA proposed cleanup criteria of 10 ppm PCB with cap for high public
contact areas, and 25 ppm PCB for reduced public contact areas. TSCA has since established cleanup
criteria for PCB spills (40 CFR 761, Subpart G), establishing requirements for decontaminating spills in
restricted and nonrestricted access areas. Nonrestricted access areas mean any area other than
restricted access, and includes residential/commercial areas. Restricted access means areas that are at
least 0.1 kilometer (km) (about 328 feet) from a residential/commercial area and limited by man-made
barriers (e.g. fences and walls). Areas where access is restricted but are less than 0.1 km from a
residential/commercial area are considered to be residential/commercial areas. In restricted access
areas contaminated soils are required to be cleaned to 25 ppm PCB by weight. In nonrestricted access
areas contaminated soils are required to be cleaned to 10 ppm PCB by weight provided that soil is
excavated to a minimum depth of 10 inches. The ROD mandated the excavation of soils contaminated
with greater than 100 ppm PCB and the construction of a cap over the site which prevents exposure to
the remaining PCB contaminated soils. As long as the cap remains in place and in good condition, there
is no exposure or unacceptable risk to on-site PCBs in soils.
27
At the time of the ROD, the Safe Drinking Water Act (SDWA) recommended maximum contaminant level
(RMCL) for TCE was 0, so a less that 1 g/L standard was established for groundwater at the site. Since
January 9, 1989 a TCE MCL of 5 g/L has been in place, and the 1993 ESD revised the groundwater
criteria for TCE from 1 g/L to 5 g/L.
Although the ROD did not reference the document as an ARAR, recommended surface water quality
criteria given in Quality Criteria for Water (EPA, 1976) was used to establish a criteria for PCB levels in
surface water of <1.0 g/L. The current treated groundwater off-site discharge criteria for PCB at Geneva
is <1.0 g/L.
Action-Specific ARARs:
Action-specific ARARs are typically technology or activity-based requirements applicable to actions
involving special categories of wastes. Action-specific requirements are usually triggered by certain
remedial activities that may be a component of the overall cleanup alternative. The following action-
specific requirements were identified in the ROD as applicable during remedial actions:
Resource Conservation and Recovery Act (RCRA) (40 CFR Part 264) – establishes technical
requirements for the surface cap, incinerators, and landfills
Location-Specific ARARs:
Location-specific ARARs are restrictions placed on remedial activities solely on the basis of the location
of the remedial activity. Some examples of locations that might prompt a location-specific ARAR include
wetlands, sensitive ecosystems or habitats, floodplains, areas of historical significance. No location-
specific requirements were identified in the ROD as applicable to the site.
Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics.
A human health risk assessment (HHRA) for PCB exposure to onsite soil was conducted at the time of
the ROD to establish a cleanup criteria for the onsite soils. Based on this assessment, the ROD
mandated the excavation of soils contaminated with greater than 100 ppm PCB and the construction of a
cap over the site which prevents exposure to the remaining PCB contaminated soils. The risk
assessment was based on methodology given in “Health Implications of 2,3,7,8-Tetrachlorodibenzodioxin
(TCDD) Contamination of Residential Soil” (Kimbrough et al, 1984). A summary of the assessment is
given in Appendix C of the Feasibility Study (FS) (IT, 1986). The risk assessment given in the FS did not
provide the toxicity values used or details on the methodology. Currently the standard methodology for
conducting risk assessments is given in Risk Assessment Guidance for Superfund (EPA, 1989) and the
PCB toxicity values for carcinogenicity were last revised in 1997. Although the methodology and toxicity
values for PCB have changed since the ROD was issued in 1986, PCB contaminated soils remaining at
28
the site are now protected from exposure by the cap and as long as the cap remains in place and in good
condition, there is no exposure or unacceptable risk to on-site PCBs in soils.
Due to the shallow depth to groundwater of the 30-foot sand unit in the area along the eastern boundary
of the site and the detected contaminants in MW-26, there is a possibility that contaminated groundwater
from the 30-foot sand unit has discharged into the channel. An evaluation of the potential for
contaminated groundwater from the site to discharge to the flood control channel should be conducted. If
there is a potential for this to occur, sampling and analysis of the channel sediments and surface water for
site contaminants should be conducted to verify the sediments and surface water are protective of human
health and the environment.
Vapor Intrusion.
Risk due to vapor intrusion in buildings was not included in the evaluation of the site in the RI/FS.
Groundwater at the site is contaminated with volatile organic compounds (VOCs) BTEX and TCE. The
current concentrations of the VOCs in groundwater at the site are not known; however, sampling in the
recovery wells in 2005 and 2006 detected benzene at concentrations up to 0.0362 mg/L, toluene up to
0.081 mg/L, ethylbenzene up to 1.4 mg/L, xylenes up to 10.4 mg/L, and TCE up to 0.008 mg/L. The VOC
contaminated groundwater in the 30-foot sand unit is contained within the slurry walls around the
perimeter of the site. The only building on site is the treatment system building which houses the
treatment plant. Because the VOC contaminated groundwater is contained onsite, the risk due to vapor
intrusion off site is minimal. However, because the treatment system building is adjacent to the slurry wall
on site there is a possibility of vapor intrusion in the building at levels above those protective of human
health. A vapor intrusion screen should be performed on the building.
There have been no changes in exposure pathways, toxicity characteristics, or other contaminant
characteristics for the Geneva site which would indicate the remedy is no longer protective of human
health and the environment. There has been no change to the standardized risk assessment
methodology that could affect the protectiveness of the remedy.
7.3 Question C: Has Any Other Information Come to Light That Could Call into Question the Protectiveness of the Remedy?
Examples of other information that might call into question the protectiveness of the remedy include
potential future land use changes in the vicinity of the site or other expected changes in site conditions or
exposure pathways. There were no new or previously unidentified risks or impacts from natural disasters
that could affect performance or protectiveness of the remedy. No additional Information has come to
light that could call into question the protectiveness of the remedy.
29
8 Issues
No. Issues
Affects Protectiveness
(Y/N)
Current Future
1 PCB concentrations exceed the MCL and are increasing in the 100-foot sand unit.
N Y
2 No cleanup criteria has been established for PCB in the groundwater. N Y
3 There is no remediation or containment of the PCB contaminated groundwater in the 100-foot sand unit.
N Y
4 There is insufficient treatment plant capacity to treat pumped groundwater from both the 30-foot sand and 100-foot sand units.
N Y
5 There has been sporadic operation of the recovery/treatment system and groundwater elevation gauging during the review period.
N Y
6
PCB concentrations appear to be increasing in MW-24 at the eastern boundary of the site in the 100-foot sand unit and PCB contaminated groundwater may be leaving the site boundaries at levels exceeding the MCL.
N Y
7 Institutional controls mandated in the 2007 ESD have not been implemented at the site.
N Y
8
Groundwater contained within the slurry wall in the 30-foot sand unit is contaminated with volatile organic compounds BTEX and TCE. The treatment system building is adjacent to the slurry wall on site and there is a possibility of vapor intrusion in the building at levels above those protective of human health.
N Y
9
Due to the shallow depth to groundwater of the 30-foot sand unit along the eastern boundary of the site and the detected contaminants in MW-26, there is a possibility that contaminated groundwater from the 30-foot sand unit has discharged into the Harris County flood control channel.
N Y
10 Based on the current information showing the groundwater flow direction in the 100-foot sand unit is to the north, there may be insufficient groundwater monitoring along the northern boundary of the site.
N Y
11
None of the monitoring wells have locks on the casing covers. The old recovery wells (RW-01 through RW-05 and RW-7 through RW-10) now used as piezometers do not have caps. Monitoring wells MW-02, MW-23 and MW-25 are missing bollards.
N N
30
No. Issues
Affects Protectiveness
(Y/N)
Current Future
12 Two monitoring wells, MW-18 and MW-02, were identified during the site inspection as being lost or abandoned.
N N
13 No O&M log was found during the site inspection. N N
14 The soil has eroded out from beneath the well pad at RW-03. N N
15 East of the deep monitoring wells, brackets holding the conduits on the stands have failed.
N N
16 Fire ant mounds were observed on the cap which could create a conduit between the ground surface and the buried wastes.
N N
17 Site documents are missing from the local site information repository, the M.D. Anderson Library on the main campus of the University of Houston.
N N
18
The March 31, 2009 sample from the CWST exceeded the PCB discharge criteria. The water was resampled on April 30, 2009 and was reported to meet the discharge criteria. This review was unable to confirm that the resampled results met the discharge criteria because the analytical results were not provided.
N N
19 There is erosion control fabric exposed at the surface at the toe of the cap at the southeast corner.
N N
20 The grate covering the floor drainage channel in the treatment plant is bent and presents a tripping hazard.
N N
21
Currently reported well depths given for MW-101 and MW-102 do not match the depths given in the original 1985 well schematics, and it appears the labels for these two wells have been switched at some point in the past. The labels for the other two deep wells MW-103 and MW-104 may have been switched also.
N N
9 Recommendations and Follow-Up Actions
No. Recommendations/Follow-up Actions
Party Responsible
Oversight Agency
Milestone Date
Follow-up Actions: Affects Protectiveness
(Y/N)
Current Future
31
No. Recommendations/Follow-up Actions
Party Responsible
Oversight Agency
Milestone Date
Follow-up Actions: Affects Protectiveness
(Y/N)
Current Future
1
An investigation of the possible mechanisms for PCB entering the deeper water bearing units should be conducted with the goal of mitigating the downward migration of PCB from the 30-foot sand unit. The investigation should include the possibility that the deep monitoring wells are the source of the downward migration of PCB.
TCEQ EPA September
2015 N Y
2
The ROD should be amended with an ESD or ROD amendment to include a cleanup criteria for PCB in groundwater.
EPA EPA September 2018
N Y
3
Recovery and treatment of PCB contaminated groundwater in the 100-foot sand unit should be conducted to prevent the further migration of PCB.
TCEQ EPA September 2015
N Y
4
The capacity of the treatment plant needs to be increased. An optimization study should be conducted to determine the best method of increasing the plant capacity.
TCEQ EPA September 2015
N Y
5
The recovery/treatment system needs to be operated on a consistent basis to maintain an inward gradient of the contaminated 30-foot sand unit within the slurry wall to prevent migration of contaminants off site. Groundwater elevation gauging is needed at least quarterly as recommended in the last five-year review to confirm the inward gradient is being maintained.
TCEQ EPA March 2014
N Y
6
Verify that no groundwater use is occurring in the 100-foot sand unit in the area of MW-24. If PCB concentrations continue to exceed the MCL at MW-24, consideration should be given to installing
TCEQ EPA ASAP N Y
32
No. Recommendations/Follow-up Actions
Party Responsible
Oversight Agency
Milestone Date
Follow-up Actions: Affects Protectiveness
(Y/N)
Current Future
additional groundwater monitoring wells downgradient of MW-24.
7 Implement ICs as mandated in the 2007 ESD.
TCEQ EPA September 2015
N Y
8 A vapor intrusion screen should be performed on the site treatment system building.
TCEQ EPA March 2014
N Y
9
An evaluation of the potential for contaminated groundwater from the site to discharge to the Harris County flood control channel should be conducted. If there is a potential for this to occur, sampling and analysis of the channel sediments and surface water for site contaminants should be conducted to verify the sediments and surface water are protective of human health and the environment.
TCEQ EPA March 2014
N Y
10
An evaluation should be made of the groundwater flow direction in the 100-foot sand unit, and a determination made as to the sufficiency of the number and location of monitoring wells along the northern boundary of the site.
TCEQ EPA September
2015 N Y
11 Monitoring wells should be locked, and missing well caps and bollards should be replaced.
TCEQ EPA September 2014
N N
12
A review of past monitoring wells used at the site should be conducted and wells that are no longer needed should be identified, located, and properly plugged and abandoned.
TCEQ EPA September 2018
N N
13 An O&M log should be maintained for the site.
TCEQ EPA ASAP N N
14 Soil erosion under well RW-03 well TCEQ EPA March N N
33
No. Recommendations/Follow-up Actions
Party Responsible
Oversight Agency
Milestone Date
Follow-up Actions: Affects Protectiveness
(Y/N)
Current Future
pad should be repaired. 2014
15
Brackets holding the conduits on the stands east of the deep monitoring wells should be repaired to hold the conduits on the stands.
TCEQ EPA March 2014
N N
16 The fire ant mounds on the cap should be mitigated.
TCEQ EPA Continuous N N
17
All site decision documents and past five-year reviews should be available for public review at the M.D. Anderson Library.
TCEQ EPA March 2014
N N
18
Copies of the sampling analytical reports should be retained to provide verification that discharge criteria are being met.
TCEQ EPA Continuous N N
19
Erosion control fabric exposed at the surface at the toe of the southeast corner of the cap should be covered with soil and grass.
TCEQ EPA September
2015 N N
20 The bent grate covering the floor drainage in the treatment plant should be replaced or repaired.
TCEQ EPA September
2015 N N
21
The depths of the deep monitoring wells MW-101, -102, -103 and -104 should be gauged to verify the currently reported depths are correct.
TCEQ EPA September
2015 N N
10 Protectiveness Statement The remedy for OU-1 concerning contaminated soil at the Geneva site is protective of human health and
the environment because the waste has been removed or contained and is protected from erosion. The
remedy for OU-2 concerning contaminated groundwater is protective of human health and the
environment in the short term because there is no evidence that there is current exposure. Twenty-one
34
issues were identified which need to be addressed for the remedy to remain protective for the long term,
and the recommendations and follow-up actions listed in Section 9 should be implemented to address
these issues. In addition to the recommendations in Section 9, site operations and implementation of
performance and compliance monitoring should continue.
Because the completed remedial actions and monitoring program for the Geneva site are protective for
the short term, the remedy for the site is protective of human health and the environment and will
continue to be protective if the action items identified in this report are addressed.
11 Next Review The next Five-Year Review, the fifth for this site, should be completed by September 2018.
35
12 References
Corrigan Consulting, Inc., 1998. Preliminary Groundwater Remediation Assessment, Geneva Industries Superfund Site. November, 1998. Harris-Galveston Subsidence District, 2013. Well Radius Report, http://www.hgsdtx.org/Forms/frmWellRadius.aspx, accessed June 28, 2013. IT Corporation, 1985a. Site Investigation, Geneva Industries, Houston, Texas. June, 1985. IT Corporation, 1985b. Deep Well Project, Volume 1, Geneva Industries, Houston, Texas. June, 1985. IT Corporation, 1986. Site Investigation Addendum Report, Geneva Industries, Houston, Texas. January, 1986. IT Corporation, 1986. Feasibility Study, Geneva Industries, Houston, Texas. April, 1986. Kimbrough, R.D, Falk, H., Stehr. P., Fries, G., 1984. “Health Implications of 2,3,7,8-Tetrachlorodibenzodioxin (TCDD) Contamination of Residential Soil”. Journal of Toxicology and Environmental Health 14:47-93, 1984. Monitoring and Remediation Optimization System (MAROS), 2006. MAROS Software Version 2.2 User's Guide. March, 2006. Shaw Environmental Inc, 2006. Final Operations and Maintenance Manual Process Treatment System. September 2006. Shaw Environmental Inc, 2010. Sampling and Analysis Plan for Operation and Maintenance Activities, Version 3.0, Geneva Industries Federal Superfund Site, Houston, Texas. July 2010. Tetra Tech EM Inc., 2003. Second Five-Year Review for the Geneva Industries Superfund Site, Houston, Harris County, Texas. September 2003. Texas Water Development Board (TWDB), 2013a. Texas Water Development Board Groundwater Database, http://www.twdb.state.tx.us/groundwater/data/gwdbrpt.asp, accessed June 28, 2013. Texas Water Development Board (TWDB), 2013b. Texas Water Development Board Submitted Driller's Reports Database, http://www.twdb.state.tx.us/groundwater/data/drillersdb.asp, accessed June 28, 2013. U.S. Environmental Protection Agency (EPA), 1976. Quality Criteria for Water. July, 1976. U.S. Environmental Protection Agency (EPA), 1986. Record of Decision, Geneva Industries. September 18, 1986. U.S. Environmental Protection Agency (EPA), 1989. Risk Assessment Guidance for Superfund, Volume I, Human Health Evaluation Manual, (Part A). December 1989. U.S. Environmental Protection Agency (EPA), 1993. Explanation of Significant Differences, Geneva Industries Superfund Site. July 1993. U.S. Environmental Protection Agency (EPA), 1998. First Five-Year Review, Geneva Industries Superfund Site, Houston, Harris County, Texas. April 1998.
36
U.S. Environmental Protection Agency (EPA), 2001. Comprehensive Five-Year Review Guidance. OSWER No. 9355.7-03B-P. June 2001. U.S. Environmental Protection Agency (EPA), 2007. Explanation of Significant Differences, Geneva Industries Superfund Site. May 2007. U.S. Environmental Protection Agency (EPA), 2008. Third Five-Year Review, Geneva Industries Superfund Site, Houston, Harris County, Texas. September 2008.
Tables
Table 1 Chronology of Site Events
Date Event
1967-1978 Site operated by Geneva Industries as a petrochemical production facility.
June 1972 - September 1978 PCB production begun at site. November 1973 Geneva Industries declares bankruptcy.
February 1974 – December 1976 Site operated by Pilot Industries. December 1976 – December 1980 Site owned by Intercoastal Refining.
September 1978 Facility operations end. December 1980 – May 1982 Site owned by Lonestar Fuel Co.
May 1982 – ? Site owned by Fuhrmann Energy. September 1983 Site proposed for inclusion in NPL. September 1984 Site placed on NPL.
October 1983 – February 1984 Planned Removal performed by EPA. September 1984 – December 1985 RI/FS performed.
September 18, 1986 ROD signed by EPA.
July 1993 ESD approved by EPA raising the TCE action level from 1 g/L to 5 g/L, and which clarifies amount of waste found and removed.
September 14, 1993 Preliminary Close-Out Report prepared. April 8, 1997 Source Control portion of the site deleted from the NPL.
April 1998 First Five-Year Review completed. September 2003 Second Five-Year Review completed.
May 2007 ESD approved by EPA including institutional controls as part of the remedy.
September 2008 Third Five-Year Review completed. February 2011 New recovery wells installed.
Table 2 Identified Water Supply Wells Within 1 Mile of Geneva
MW-26 30-foot sand unit Benzene 11 7 1.58 -33 99.5% No D
MW-26 30-foot sand unit Trichloroethene 11 4 2.30 -30 99.0% No D
MW-26 30-foot sand unit Vinyl Chloride 6 2 1.23 -1 50.0% No NT
MW-26 30-foot sand unit Total PCB 11 7 1.37 -27 98.0% No D
MW-24 100-foot sand unit Vinyl Chloride 6 3 1.22 3 64.0% No NT
MW-24 100-foot sand unit Total PCB 11 3 2.10 -3 56.0% No NT
MW-102 100-foot sand unit Total PCB 11 11 1.60 25 97.0% No I
MW-22 100-foot sand unit Total PCB 11 1 0.54 -18 90.5% No PD
MW-101 250-foot sand unit Total PCB 6 3 1.23 3 64.0% No NT
MW-104 700-foot sand unit Total PCB 7 3 2.31 0 43.7% No NT
Note: Increasing (I); Probably Increasing (PI); Stable (S); Probably Decreasing (PD); Decreasing (D); No Trend (NT) MAROS determines trends based on the following Mann-Kendall analysis decision matrix.
Mann-Kendall Statistic
Confidence in Trend
Concentration Trend
S > 0 > 95% Increasing S > 0 90 - 95% Probably Increasing S > 0 < 90% No Trend S ≤ 0 < 90% and COV ≥ 1 No Trend S ≤ 0 < 90% and COV < 1 Stable S < 0 90 - 95% Probably Decreasing S < 0 95% Decreasing