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The San Jacinto River Waste Pits Site (Site) is on the western bank of the San Jacinto River, in Harris County, Texas, located near the Interstate Highway 10 (I-10) bridge over the San Jacinto River. The waste pits were constructed in the 1960s for disposal of pulp and paper mill waste. The Site was placed on the National Priorities List (Superfund) in March of 2008. The U.S. Environmental Protection Agency is currently evaluating remedial alternatives to address contamination at the Site.
This website contains publicly available information about the San Jacinto Waste Pits project. It is provided for community information purposes by the companies involved in the Site's remediation: International Paper and MIMC.
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San Jacinto River Surface Water Data
To U.S. EPA Region 6:
As you prepare for the upcoming December 4 public meeting, Respondents request that EPA clarify statements – in the Record of Decision (ROD) and in recent news stories and public meetings – suggesting that higher concentrations of dioxins and furans in surface water above the TCRA cap indicate that the cap is “leaking.” Those statements are not accurate.
Higher concentrations of dioxins and furans in surface water above the TCRA cap than in surface water upstream of the TCRA cap is due to dioxins and furans from other sources and their presence in sediments within the Preliminary Site Perimeter. Those other sources include:
These contributing factors are discussed in more detail in the submissions listed below, and include the Draft Interim Final Feasibility Study (Anchor QEA 2014), the Remedial Investigation Report (Integral and Anchor QEA 2013), the 2016 Surface Water Sampling and Analysis Plan (Integral and Anchor QEA 2016a), and the Data Summary Report: 2016 Studies (Integral and Anchor QEA 2016b).
The direct discharges include two permitted wastewater outfalls along the eastern shore of the San Jacinto River north of I-10 and within USEPA’s Preliminary Site Perimeter.
Separately, porewater studies of the TCRA cap (Integral and Anchor QEA 2013, Integral and Anchor QEA 2016b) have shown that the cap is effective is preventing migration to surface water of dioxins and furans in the capped materials. Please do not hesitate to contact me if you would like to discuss.
UPDATE: ADDITIONAL SAMPLING SHOWS NO RELEASE FROM SAN JACINTO WASTE PITS
Statement From McGinnes Industrial Maintenance Corp. (MIMC) Regarding the U.S. EPA’s Record of Decision
We cannot support a plan for the site that provides less protection to all affected communities than the existing cap already has provided. We are deeply concerned that the decision announced today could result in a release to the San Jacinto River and downstream areas. We disagree with EPA’s claim that the local or downstream areas can be protected during removal. We will review U.S. EPA’s Record of Decision in its entirety.
Excerpt: "This letter and the enclosed reports and memoranda are based upon either an event (Hurricane Harvey) that occurred after the close of the public comment period on the PRAP or on a document, the October 2, 2017 USEPA Region 6 Memorandum, that was submitted to the Remedy Review Board following the close of the common period."
Excerpt: "Hurricane Harvey was certainly an “ultra-extreme” event, and should be considered a defining ultra-extreme event…The Time Critical Removal Action (TCRA) cap withstood the forces of Harvey, with only small areas of the TCRA armor being affected. "
Excerpt: "Hurricane Harvey was an extreme event and its occurrence creates an unusual opportunity to test assertions regarding long-term stability of the TCRA Armored Cap in the face of extreme hydrologic events and stresses. "
Excerpt: "Results of the evaluation confirm that Harvey was an extreme flood event with high velocities acting over the Armored Cap. Based on the modeling performed, it does not appear that Harvey produced higher forces on the Armored Cap than the large range of storm conditions simulated as part of both the TCRA (Anchor QEA 2010) and Draft Feasibility Study (Anchor QEA 2014). "
Excerpt: "Because it does not mention the TCRA armored cap, Region 6 also does not acknowledge that its preferred remedy for removal necessarily involves removal of that functioning cap – something that has never been done before and involves technical challenges and risks that were detailed in Respondents’ comments on Region 6’s Proposed Remedial Action Plan (Proposed Plan). "
Much attention is currently focused on how to permanently remediate the San Jacinto waste pits off Interstate 10 in eastern Harris County. Now is a critical time to be sure that the very real and measurable risks associated with one of the options — full excavation of the site — are clearly understood by those who live either nearby or downstream from this area.
Fortunately, people in the community anxious about what decision is made don’t have to take the word only of advocates — either those who call for uncovering the contaminated material through dredging or those who prefer the site remain fully capped, upgraded and then sealed permanently.
Recently, the U.S. Environmental Protection Agency turned to the U.S. Army Corps of Engineers to independently assess and model the effects of each of the proposed permanent remedies: capping vs. removal. For the first time, the Corps studies even included analysis of a newer alternative not previously studied. That option is to deploy what’s known as enhanced “Best Management Practices” (BMPs), which involves constructing barriers that seek to enable excavation to take place “in the dry.”
Unfortunately, these removal solutions were found by Army Corps’ experts to be far from risk-free. According to the full report, just released to the public in August, “... full removal ... would be expected to significantly increase short-term exposures to contaminants.”
Even more concerning, if flooding occurs during remedial construction — even with enhanced BMPs deployed — the report says “releases may be up to five times greater” if these barrier structures were overtopped. Worse, if a storm were to occur “during the actual removal/dredging operation, the likelihood of extremely significant releases of contaminated sediment occurring is very high,” the report states.
In addition, the Army Corps’ report explains that for several years after removal, fish tissue contamination in the river will be dozens of times greater than under current conditions with removal using enhanced BMPs. The report even acknowledges that after removal of the existing cap and underlying material, dioxin-impacted material would still remain in place at the site. It concluded “... short-term releases [of residuals] ... would subsequently be available for redistribution during erosion events from high flows or storm events.”
Natural environmental recovery of the area from these contaminants, now occurring, would also be delayed by 10 to 20 years, the report says.
In contrast, the Army Corps report concludes that enhancing the current armored cap would be highly effective in permanently preventing releases of contaminants to the environment. It notes that, when compared to capping, “ ... short-term releases for the new full removal [alternative] is about 400,000 times greater than the releases from the intact cap.”
A new set of sampling results just released reinforces that the current cap is working. These results — validated and submitted to the EPA — measured samples taken from sediment surrounding the cap, groundwater underneath the capped site, surface water above and around the site, and porewater in the crevices of the rocks that comprise the cap. Dioxin concentrations from within the waste pits were not detected in either the groundwater or porewater samples. In short, the existing cap is preventing release of dioxin into the environment. Fish tissue samples from around the site also show that dioxins in these fish are at levels similar to other fish found both upstream and downstream from the waste pits. And we all know the San Jacinto River contains various other dioxins not related to the waste pits.
Before settling on a final decision about the best remedy for the site, EPA will follow Superfund protocol and take into account all verifiable data — not solely public opinion and the assortment of points of views expressed by observers. (The latter are only one of nine Superfund criteria evaluated.) The independent expert analysis of alternatives by the Army Corps, together with the new results from recent sampling of the site mandated by EPA, point to what is scientifically required to remediate the pits.
Baytown Sun Article
By Ken Haldin (10/8/16)
There's no shortage of opinions about the fate of the San Jacinto waste pits site off Interstate 10 in Harris County.
This area of the San Jacinto River has been impacted for decades by numerous pollution sources. The San Jacinto waste pits themselves are the legacy of paper mill-related disposal operations that occurred five decades ago - with a design, construction techniques and at a location approved by Harris County.
As one of two companies working with the U.S. Environmental Protection Agency on the waste pits, we have a deep interest in ensuring that none of the encapsulated material is released into the river. We also think it's vitally important that the facts regarding the site's present state and future cleanup are known and understood by the public.
Years of site-related data have been compiled by EPA to ensure the Superfund process concludes safely. As residents weigh the pros and cons of choices for the final cleanup, we believe all of the facts - including recent new information - need to be shared.
An armored cap was completed at the site in 2011 to encapsulate the underlying paper mill waste. However, while data were still being collected to test the cap's effectiveness, some voices had already turned to a different alternative for the final site remedy: full excavation and removal.
Promoting removal before all the information needed to select a remedy has been reviewed does everyone a disservice. No one wants contaminants, now buried under a cap proven stable by newly available environmental sampling data, to be released into the surrounding waterway. Those who work on or around the San Jacinto River and those who live nearby or downstream deserve to make their own judgments, using the best information available.
The EPA asked the U.S. Army Corps of Engineers for the agency's expertise and independent advice on the final remedy. The Corps' report, which responds to those who demanded independent data about capping versus removal, shows removal to be far riskier than permanently capping the site. According to the report, "full removal ... would be expected to significantly increase short-term exposures to contaminants."
More alarming, if flooding occurs during the removal (estimated to take at least a year and a half), even when using enhanced removal techniques, "releases may be up to five times greater." And if a storm occurred "during the actual removal/dredging operation, the likelihood of extremely significant releases of contaminated sediment occurring is very high," the report states.
There's more. Contamination of river fish tissue may be dozens of times greater with removal (again, even using enhanced techniques) and natural environmental recovery of the area, now occurring, will be delayed by 10 to 20 years, the report says.
What about capping? Can a containment structure withstand nature's forces? Yes, says the Corps report. Enhancing the cap with specific improvements the agency recommends would be highly effective.
One of the often-repeated criticisms of the cap made by removal advocates is that an Ike-like hurricane, or worse, might wipe away as much as 80 percent of the armored cap. What's ignored, however, is that this finding doesn't apply if the Corps-recommended enhancements to the cap are made. To quote the report: "These issues related to cap permanence can be addressed by additional modifications."
Although cost is one of EPA's nine criteria for evaluating a Superfund site, some have claimed cost is the key driver for us. Not true. What's essential to us is the safety and effects of the remedy chosen. What is unusual about this site is that full removal of the existing armored cap and the underlying waste is the most expensive remedy, yet results in significantly more releases to the environment, making it actually the least cost-effective remedy in the long run.
We appreciate and understand the concerns of the community, and we certainly don't want contaminants from the waste pits released into the river. We fear, however, that those advocating for full removal without having or conveying key scientific data about the effectiveness of the cap to date or the effects of cap removal, do the community a disservice. So we urge everyone to take a closer look at the real risks stated in the Corps report.
During the comment period prior to EPA's selection of the final remedy, respectfully sharing what the science and technical data say about protecting the environment, local citizens and potentially impacted communities, is in everyone's best interest.
Since its inception in 2009, Haldin has been a member of the EPA Region 6 Community Awareness Committee for the San Jacinto Waste Pits, representing McGinnes Industrial Maintenance Corp (MIMC). MIMC is one of two companies to date working with EPA on final cleanup of the San Jacinto Waste Pit.
Houston Chronicle Article