If you'd like to be notified when this website is updated with new content or documents, please enter your email below.
Your message was sent succssfully! I will be in touch as soon as I can.
Something went wrong, try refreshing and submitting the form again.
Documents for the San Jacinto project can be found and read/downloaded from this page.
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). "
Excerpt: "The TCEQ cannot support the preferred remedy at this time without a further evaluation of the short-term risks and the uncertainties associated with the implementation of the preferred remedy."
This document contains response to to EPA's Proposed Plan for San Jacinto River Waste Pits Superfund Site by MgGinnes Industrial Maintenance Corporation (MIMC) and International Paper Company (IP)
Excerpt: “In no uncertain terms, when evaluated against the NCP criteria, Alternative 3aN is the preferred remedy and there is simply no factual, scientific, regulatory, or legal basis for EPA' s determination that Alternative 6N should be the preferred remedy for the Northern Impoundments. "
Summary: According to a CPF Associates Inc. scientific study, a proposed federal remedy plan for the San Jacinto waste pits site located off Interstate 10 in east Harris County is based on multiple scientific errors, is contrary to U.S. Environmental Protection Agency guidelines and creates increased complexity and risk of failure, all of which render the proposed remedy not protective of human health and the environment.
Excerpt: "Available results for these multiple lines of evidence indicate that the TCRA armored cap and the conditions south of I-10 are effective in preventing the release of dioxins and furans in the wastes into the environment."
Excerpt: “An enhanced Armored Cap is expected to be stable and highly effective in controlling the transport of contaminants and reducing the exposure concentration of contaminants in the water column... Removal of the Armored Cap and materials beneath it would create significant risk of substantial releases of waste materials to the San Jacinto River."
Appendix A: Review of Proposed Remedial Action Plan by Michael R. Palermo
Michael R. Palemero is a consulting engineer with experience in Dredged Material Management and Contaminated Sediment Remediation since 1974, serving both private sector and government clients. Read full bio and comments by downloading this document here.
Appendix B: Review of the Current Cap and Proposed Remedies by Danny D. Reible, Ph.D.
Danny D. Reible, Ph.D. has approximately 30 years of experience with contaminated sediments and particularly management via in-situ remedial approaches. Read full bio and comments by downloading this document here.
Appendix C: Comments on the United States Environmental Protection Agency’s Proposed Remedial Action Plan by Ancil Taylor and Craig Vogt .
Ancil Taylor has over 38 years of direct experience in the field of marine dredging and related marine issues. His experience includes numerous coastal restoration projects along the Gulf and East coasts of the United States. Craig Vogt Inc provides environmental consulting for regulatory and non-regulatory issues dealing with the wide range of ocean and coastal environmental issues. Read full bio and comments by downloading this document here.
Appendix D: Examination of Selected Assertions by U.S. EPA in the Proposed Plan by Doug Shields, Jr., Ph.D.WRE
Doug Shields has 40 years of experience in water resources and environmental engineering, including 12 years for the U.S. Army Corps of Engineers and 22 years as a Research Hydraulic. Read full bio and comments by downloading this document here.
Appendix E: Documents Related to Requests for Extension of Comment Period and FOIA Requests and Not Included by Region 6 in the Administrative Record.
Click here to download Appendix E.
Appendix F: Documents Related to Region 6's
Request to Respondents for Additional Data Collection and Not Included by Region 6 in the Administrative Record
Click here to download Appendix F.
Appendix G: Additional Documents not included by Region 6
in the Administrative Record
Click here to download Appendix G.
Appendix H: 2016 Data Summary Report
Click here to download Appendix H.
Sediment Management Work Group (SMWG)’s Comments on the San Jacinto Site Proposed Plan for the Administrative Record for the Site
Click here to download this document.
Comments filed with Region 6 by the Superfund Settlements Project/ RCRA Corrective Action Project.
Click here to download this document.
Excerpt: "Available results for these multiple lines of evidence indicate that the TCRA armored cap and the conditions south of I-10 are effective in preventing the release of dioxins and furans in the wastes into the environment."
The EPA has posted several documents pertaining to the EPA Proposed Plan. Use the links below to view documents, including the plan, on the EPA website.
View Proposed Plan Documents on EPA Website»
Read/Download Proposed Plan from EPA»
Excerpt: “The evaluations performed to address the effectiveness of the existing repaired TCRA cap with the proposed modifications outlined in the capping Alternative 3N showed that the cap is expected to be highly effective in controlling the flux of contaminants and reducing the exposure concentration of contaminants in the water column.
Excerpt: “...the short-term releases for the new full removal Alternative 6N is about 400,000 times greater than the releases from the intact cap for the same period and area and about 2500 times than the releases from stable sediment of the same area...”
Excerpt: "The Armored Cap continues to perform as designed and consistent with USEPA guidance, adding to the evidence demonstrating its continued protectiveness. Since June 2014, several significant high water events have occurred in the San Jacinto River, including a 10 to 20-year flood during April 2016 (USGS, 2016), with no observed adverse effect on the Armored Cap."
Short document showing additional security measures at the San Jacinto site.
Excerpt: "The Potentially Responsible Parties began installation of eight ground water monitoring wells this week in the northern waste pits area (four total) and the Southern Impoundment area (four total); installation of the new wells will be completed next week. Installation of the camera monitoring system was completed last week and the system is now operational with monitoring 24 hours per day and 7 days per week."
Excerpt: "EPA is committed to ensuring that those who are responsible for hazardous waste sites take the lead in cleanup, when appropriate, throughout the Superfund cleanup process. This 'Enforcement First' approach has proven to be effective at increasing the number of PRP-lead Remedial Action starts at non-Federal facility sites. With this memorandum, Regions are encouraged to increase the number of PRP-lead RI/FSs."
"To date, EPA’s experience has shown that, with adequate oversight, PRPs can perform acceptable RI/FSs. A detailed and thorough Statement of Work (SOW) helps ensure an adequate RI/FS by setting forth work and deliverable requirements, specifying procedures and relevant guidance documents, and establishing oversight expectations."
Excerpt: "DSHS concluded that at this time an in-depth epidemiologic study of health outcomes is not recommended... Past analysis of available environmental data collected in the SJR area have not identified a specific problem that would validate conducting a community wide health study."
Describes site background, contaminants, water quality, residential soil sampling, containment in capped areas, and community engagement.
Excerpt: "The wastes in the impoundments are effectively contained by the temporary armored cap installed in 2011. Sampling indicates that the wastes are not leaking, and visual inspections as well as elevation surveys show that the cap is intact and stable."
Respondents present site history, cleanup actions, results, and next steps.
Excerpt: "The site’s permanent protection and future needs are being thoroughly reviewed and are addressed via EPA’s rigorous process."
NRRB Cover Letter describing the San Jacinto site and Armored Cap solution
Excerpt: "The armored cap should be effective and protective on a long-term basis, as has been the case of numerous other caps installed in this country and worldwide. As with any remedy, post-construction monitoring should continue to be required to ensure that construction meets design performance."
Watch an animation about the recently completed repair work at the site. Click here to view/download the video.
Read more about sites throughout the country that have implemented successful, functioning caps
Watch a short video illustrating the armored cap at the San Jacinto Site.
(9/28/16)
"We strongly disagree with the proposed remedy put forth by the EPA. We are looking for the solution that best protects the environment and public health. We do not understand why the EPA would completely ignore their own consultant’s report, prepared by the Army Corp of Engineers, that concludes that removal of the wastes could significantly damage the environment and public health. It is disappointing that the EPA has apparently decided to ignore science and technical data. Excavation will result in resuspension of the material, worsening the river and putting nearby communities at risk for years to come. The Army Corps report and subsequent EPA-required testing around the site make clear that retaining and fortifying the cap – making it even stronger and permanent – is the best way to protect the river and surrounding communities. The sampling results demonstrate that no dioxin from waste is moving from the waste pits into groundwater below the pits or into surface water above the pits. We'll carefully review the EPA’s proposed remedy and maintain our focus on ensuring that the ultimate remedy fully protects public health and the environment. Together with the potentially affected communities and other groups interested in protecting the environment, we will work to make sure that the ultimate remedy follows the best science and technical data to protect the environment and citizens of Texas."
