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Preliminary 30% Remedial Design Submitted for Northern Impoundment

7/14/20

The Preliminary 30% Remedial Design (RD) document for the Northern Impoundment for the San Jacinto River Waste Pits was submitted to EPA Region 6 on May 28.

• The 83-page planning document outlines and details the rigorous investigation, engineering studies and analyses underlying the design options for remediation of the waste pits.
• The remedial design reflects input from a Technical Working Group consisting of representatives from the EPA, Texas Commission on Environmental Quality (TCEQ), the U.S. Army Corps of Engineers (USACE), the Responsible Parties’ consulting engineering firm and other technical subject-matter experts. Ten meetings of this group took place – dating back to April 2018 and continuing through April 2020 – to provide expertise in the development and evaluation of the design.
• The objective of the “30% RD” is to present a summary of findings and criteria for a remedial design to be considered under the EPA’s oversight for the site. The milestone report reflects two previous phases of pre-design investigation, treatability studies of both waste and water, and recent findings about the depth of waste and underlying soil contained within the current armored cap area.
• The report also describes in detail primary design elements and complexities involved in executing the remedy selected by EPA for the Northern Impoundment in the Record of Decision dated October 2017. These include the design and installation of a proposed engineered barrier using best management practices as well as waste material excavation and removal methodologies for five waste cells, water management and treatment, worker and community health and safety, duration of the remediation, off-site waste transport, and conditions expected at the site following remediation.

Associated design drawings, specifications and supplemental plans are also included in the report.

The complete document can be found at: https://semspub.epa.gov/src/collection/06/SC32193

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Update from EPA Region 6 for Community Awareness

9/18/19

Due to the threat of flooding associated with the tropical disturbance in the Gulf of Mexico, the contractor for the responsible parties has stopped the field work for the Phase 2 Pre-Design Investigation effective Tuesday. The site has been secured. Field work could resume on Friday depending on the movement of the tropical depression.

Following actions were taken to secure the open area in the Western cell:

1. Work in this area has been completed and the excavation has been filled;
2. The contractor that does repairs to the liner was scheduled to weld the HDPE liner patch this morning but was not able to do the work due to the rain. In the meantime the following actions were taken to secure this area:
   1. The HDPE liner patch was placed over the area that was excavated;
   2. The HDPE liner patch was taped to the existing liner using 4” PVC tape made for that type of liner;
   3. Sandbags have been placed on top of the HDPE liner;
   4. A berm was constructed around the area of the excavation.

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Site Activity Under 2nd Phase Pre-Design Investigation Set to Begin

8/27/19

• Second Phase Pre-Design Investigation (PDI-2) field work is scheduled to begin at the San Jacinto River Waste Pits site.
• Activity at the Superfund site will be visible for the next approximately 8-10 weeks.
• Between Aug. 28-29, equipment will be mobilized at the site. That will be followed by field work occurring over the ensuing several weeks beginning the week of Sept. 2.
• All activity is in connection with the PDI-2 work plan approved on Aug. 8 by the EPA Region 6. This design-related work will be performed by a contractor for the Potentially Responsible Parties under the oversight of EPA and Texas Commission on Environmental Quality.
• This site work is part of a comprehensive remedial design to ensure waste is safely and properly contained during future construction and removal of underlying material.
• Further updates will be provided as site activity continues.

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Northwest Slope Maintenance Scheduled to Begin

5/15/19

The Companies have voluntarily proposed enhancement to the NW corner of the San Jacinto River Waste Pits site.

• The proposed work, with activity scheduled to begin on Monday, May 20, is to enhance the NW slope pending completion of construction and removal.
• This work provides enhanced protection and is an investment that allows focus to be maintained on the Remedial Design. It is an interim enhancement until Remedial Action.
• The project has been designed for safe and efficient removal once the project moves to Remedial Action.
• GHD is the current consultant for the Remedial Design. Through a separate proposal process, GHD has also been chosen for this enhancement work. In terms of past performance, GHD successfully installed approximately 40,000 square yards of similar articulated block mats in 2018 (approximately 10 times the quantity of the San Jacinto project) in Bayou d’Inde near Sulfur, Louisiana.

Click here to view the NW Area Repair from SJRWP Presentation from EPA Region 6.

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Cap Maintenance Work Now Under Way At San Jacinto Waste Pits

7/20/18

• In response to sampling results submitted to EPA on June 28, a detailed maintenance work plan focusing on the northwestern area of the site’s northern impoundments was submitted to the Agency on July 6. EPA authorized the performance of initial field tests on July 6 and provided final approval of the maintenance plan on July 12.
• The maintenance activities proposed by the Companies went beyond restoring those discreet areas requiring maintenance and recommended the placement of geotextile and geogrid panels, overlaid with 12 inches of rock armoring across the entire maintenance area to enhance the integrity and performance of the existing rock cap.
• Field tests to obtain data needed to model and test construction means and methods for effectively addressing the designated maintenance area were subsequently completed during the week of July 9. It was determined that this activity could be performed safely and in a timely manner via land. The data collected were shared with EPA.
• Equipment mobilization by a sub-contractor firm specializing in this type of physical on-site work began Monday, July 16.
• Depending on weather, it is anticipated that this initiative will require at least two weeks for completion. EPA employees have been on site overseeing performance of this work.

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Statement from McGinnes Industrial Maintenance Corp. (MIMC) on EPA's remedial design agreement announcement

4/9/2018

MIMC has engaged constructively with the EPA throughout its process to identify the remedy for the San Jacinto Superfund site. We will continue to work collaboratively with the Agency and other responsible parties to ensure a safe, protective and effective remedial design for the site.

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Statement from International Paper (IP) on EPA's remedial design agreement announcement

4/9/2018

"The company is committed to protecting public health and the environment and we believe that remediation planning for the San Jacinto site must be rigorous, transparent and science-based and lead to engineering standards that will protect the river and the community. We look forward to continuing to work with the EPA and other stakeholders to perform the remedial design under the administrative order."

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San Jacinto River Surface Water Data

12/4/2017

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:

• direct discharge sources of dioxins and furans to surface water from a variety of permitted wastewater and stormwater outfalls in the immediate vicinity of the TCRA cap and other regional sources of dioxins and furans. Wastewater effluent and urban stormwater are known sources of dioxins and furans as well as PCBs (Paustenbach et al. 1996; Lubliner 2009; Howell et al. 2011a; University of Houston and Parsons 2006)
• dioxin and furan concentrations in tidal water coming up from the Houston Ship Channel that are generally higher than those in upstream areas of the San Jacinto River.

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.

• One is along the eastern shoreline north of I-10 and is a stormwater outfall for a large area to the east and north (see Figure 3-21 from the RI). This stormwater outfall occurs directly to the east of the small island that is northeast of the impoundments north of I-10.
• The other is from the Baytown Water Treatment Authority, on the eastern shoreline directly north of I-10 and directly across from the TCRA cap.

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.

Read More/Download

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Statement From McGinnes Industrial Maintenance Corp. (MIMC) Regarding the U.S. EPA’s Record of Decisions

10/11/2017

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.

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Update: Additional Sampling Shows No Release from San Jacinto Waste Pits

10/19/2017

• No release of dioxins or furans has occurred from the San Jacinto waste pits site as a result of Hurricane Harvey, according to results from new sampling of sediments from the site as ordered Sept. 29 by the EPA.
• The sediment sampling was required by the Agency to confirm whether any releases of these contaminants occurred from within areas in the northwest part of the cap recently sampled, including one location found with underlying waste material exposed.
• The new results confirm that no migration from the originally sampled area occurred post-storm. That location had a thin cap layer with 2-4 inches of aggregate cap material covering the waste contained below.
• As the EPA noted on 9/28, dioxin in the waste material does not dissolve easily in water. In the new sampling results, dioxins and furans were found to be well within the range of concentrations of these toxins measured in sediment in the area prior to Hurricane Harvey and found in background levels generally in the San Jacinto River.
• Sediment sampling results were provided Oct. 18 to the EPA. The new sampling was conducted in areas with sediment accumulation over the cap and past its edge in the northwestern area of the site. Full report read/download.

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Hurricane Harvey Update #6

9/28/2017

• The existing armored cap at the San Jacinto River Waste Pits Superfund Site was constructed pursuant to EPA directives as a temporary measure until a final remedy could be selected for the Site. The existing cap was designed to withstand a 100-year flood event. The existing cap was recently subjected to Hurricane Harvey, a 500- to 1,000-year storm event.
• Following Hurricane Harvey, visual, bathymetric and topographic surveys, as well as probing inspections and environmental sampling, were conducted to evaluate the integrity of the existing cap and it was determined that the cap performed exceptionally well.
• Based on all of these post-storm assessments, no evidence exists that there was any release of waste material to the environment as a result of Hurricane Harvey. The assessments also demonstrate that the existing armored cap performed well.
• The performance of the existing cap under the storm conditions created by Hurricane Harvey strongly demonstrate that the greatly enhanced and fortified cap proposed by the U.S. Army Corps of Engineers and supported by the responsible parties at the Site would provide long-term protectiveness at the Site against future extreme storm events. The enhanced and fortified cap would utilize 15-inch diameter stone that is up to 3 to 4 times the size of the stone on the interim cap.
• The probing inspection involved testing the cap surface at approximately 735 locations to ensure the continued integrity of the cap below the water surface. Based on this inspection, 28 samples were collected on Sept. 15 and analyzed for dioxins. Of the 28 samples collected, 26 are in the normal range of background concentrations for dioxin and furan in river sediments surrounding the armored cap, and two are above background levels. These two samples that are above background levels are duplicates from the same location. This single location is described in the probing inspection as having 2-4 inches of aggregate cap material in an area that represents 0.00016 percent of the total armored cap surface. With EPA approval, additional cap materials were placed at this location as part of cap maintenance activities performed during the week of Sept. 17, 2017. All other areas had cap material confirmed to be in place during the probing inspection.
• Prior to the probing inspection, EPA directed the sampling of sediment and water at the Site on Sept. 7 and 11, 2017. These samples had dioxin concentrations similar to concentrations observed in the river prior to Hurricane Harvey.

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Hurricane Harvey Update #5

9/18/2017

• Inspection of submerged portions of the armored cap under EPA supervision continued during the week of Sept. 11. Probing tools were being used to measure and ensure cap thickness underwater along the eastern portion of cap, which is ordinarily partly submerged. (Flood waters there have receded.)
• Bathymetric survey measurements, which are usually conducted quarterly as part of regular cap monitoring, were expedited and completed. Results will be reported to the EPA. Bathymetric measurements are taken to study the river bed’s topography and evaluate significant changes or movement beneath surface water.
• In addition, an EPA dive team worked last week on further inspection of the site under the EPA's direction.
• In a small number of areas where the current layer of armored cap is thinner than required (approx. 195 square feet of a 15.7-acre cap), maintenance activity began on Saturday, Sept. 16. There was no evidence of a release from any of these areas.
• Sampling of sediment in these areas, as directed by the EPA on Friday, Sept. 15, has been completed. Final sampling results will be provided to the Agency once validated.
• Work to replenish rock material on berms on the southern side of the site, located outside the waste containment areas and that do not cover the waste pits, is complete.
• Buoys recovered in the area have been secured and re-installed. Permanent site fencing repairs are nearing completion. Replacement of surveillance system cameras where needed proceeds.

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Hurricane Harvey Update #4

9/8/2017

• Site photos (new and historical) of berm areas outside the armored cap as provided to EPA Region 6 on 9/1.

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Hurricane Harvey Update #3

9/4/2017

• Further on-site inspection today confirmed earlier preliminary surface observations — the Armored Cap is intact and no waste was exposed.
• Flood waters have receded. One-third of the cap is above water and two-thirds below.
• A limited amount of stone material associated with berms surrounding the cap has moved. However, these berms — which ring the perimeter of the cap — do not have any waste material within or beneath them.
• Maintenance, including placing new geotextile and stone reinforcement on the berms, is under way. These activities were planned for in the site’s ongoing Operation, Monitoring and Maintenance Plan (OMM), and materials to complete this work are stockpiled locally.
• Other site security actions are expected to proceed in the coming days, such as any needed repairs to fencing. Additional inspection activity, including a bathymetric survey and probing under water, will take place per the OMM plan.

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Hurricane Harvey Update #2

9/2/2017

• A team of contractor specialists was able to safely access the waste pits site Friday afternoon to visually inspect the site.
• Preliminary inspection of the visible portions of the cap indicated the waste beneath remained in place following the storm.
• Berms located outside the waste footprint were also found to remain in place. Some stone material above the geo-fabric covering parts of these berms was displaced.
• As required in the EPA-approved Operations, Monitoring & Maintenance Plan, a comprehensive inspection will be conducted once water recedes.
• Various contractor specialists will return to the site to continue inspection, assess repositioning any berm cover fabric, replace stone cover as needed, plus assess fencing and camera maintenance needs.

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Hurricane Harvey Update #1

8/30/2017

• Given the scope and breadth of Hurricane Harvey, the San Jacinto waste pits site continue to be closely monitored.
• As part of this site’s operations, monitoring and maintenance plan, we regularly communicate ongoing status of the site to the EPA Region 6. On-site physical inspections are not possible to conduct safely at this time and until local transportation corridors in the general area and site itself become accessible again.
• Prior to the storm’s approach, preparations for monitoring the site and post-storm inspections were put into place according to EPA's requirements. Prevailing U.S. Coast Guard advisories were also monitored.
• Importantly, the thick armored cap currently covering the waste pits has been effective in safeguarding the site since its completion in 2011. The most recent sampling results from within the site — validated and submitted to the EPA — found the existing cap is preventing release of dioxin into the environment.
• More information about the site and the armored cap now in place there can be found on this website. When possible, relevant and timely updates will be posted here as well.

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Editorial From McGinnes Industrial Maintenance Corp: Enhancing armored cap over San Jacinto River toxic waste can be safe, effective remedy

10/14/16

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.

Source:
Baytown Sun Article

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MIMC: Enhancing armored cap over San Jacinto River toxic waste can be safe, effective remedy

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.

Source:
Houston Chronicle Article