Fourth Five-Year Review Report for the Geneva … · 2020-06-05 · Fourth Five-Year Review Report for the Geneva Industries/Fuhrmann Energy Superfund Site Houston, Harris County,

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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Attachment Not Included

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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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Table of Contents

1 INTRODUCTION .................................................................................................................................. 1

2 SITE CHRONOLOGY .......................................................................................................................... 2

3 BACKGROUND ................................................................................................................................... 2

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 REMEDIAL ACTIONS ......................................................................................................................... 5

4.1 REMEDIAL ACTION OBJECTIVES .......................................................................................................... 5 4.2 REMEDY SELECTION ........................................................................................................................... 6 4.3 REMEDY IMPLEMENTATION .................................................................................................................. 6

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

6.3.1 Groundwater Elevations ........................................................................................................ 14 6.3.2 Groundwater Sampling Results ............................................................................................. 16 6.3.3 Groundwater Treatment Plant Effluent .................................................................................. 17 6.3.4 Water Supply Wells ............................................................................................................... 18 6.3.5 Conclusions ........................................................................................................................... 19

6.4 INTERVIEWS ..................................................................................................................................... 21 6.5 SITE INSPECTION .............................................................................................................................. 23

7 TECHNICAL ASSESSMENT ............................................................................................................. 24

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

8 ISSUES .............................................................................................................................................. 29

9 RECOMMENDATIONS AND FOLLOW-UP ACTIONS ..................................................................... 30

10 PROTECTIVENESS STATEMENT .................................................................................................... 33

11 NEXT REVIEW ................................................................................................................................... 34

12 REFERENCES ................................................................................................................................... 35

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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


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.



Implementing Party

Oversight Party

Milestone Date

No Yes EPA EPA September 2018


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.



Implementing Party

Oversight Party

Milestone Date

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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.



Implementing Party

Oversight Party

Milestone Date



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.



Implementing Party

Oversight Party

Milestone Date

No Yes TCEQ EPA March 2014


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.



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.



Implementing Party

Oversight Party

Milestone Date


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.



Implementing Party

Oversight Party

Milestone Date



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.



Implementing Party

Oversight Party

Milestone Date



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

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Protectiveness Protectiveness Party Party Date



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.



Implementing Party

Oversight Party

Milestone Date

No No TCEQ EPA September 2014


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.



Implementing Party

Oversight Party

Milestone Date



Issue: No O&M log was found during the site inspection.

Recommendation: An O&M log should be maintained for the site.



Implementing Party

Oversight Party

Milestone Date

No No TCEQ EPA ASAP


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

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Protectiveness Protectiveness Party Party Date

No No TCEQ EPA March 2014


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.



Implementing Party

Oversight Party

Milestone Date



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.



Implementing Party

Oversight Party

Milestone Date

No No TCEQ EPA Continuous


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.



Implementing Party

Oversight Party

Milestone Date



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



Implementing Party

Oversight Party

Milestone Date

No No TCEQ EPA Continuous


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.



Implementing Party

Oversight Party

Milestone Date



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.



Implementing Party

Oversight Party

Milestone Date



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.



Implementing Party

Oversight Party

Milestone Date


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.

Operable Unit: 2

Protectiveness Determination: Short-term Protective


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.

Protectiveness Determination: Short-term Protective


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

Onsite soil PCB concentration of 25 ppm, 50 ppm, 100 ppm

Surface water Minimal PCB in runoff (< 1.0 g/L)

Groundwater 30-foot sand Existing concentration offsite TCE < 1.0 g/L onsite

6

Pathway Criteria

Groundwater 100-foot sand TCE < 1.0 g/L

4.2 Remedy Selection

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;

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 (EPA,

1986).

In July 1993 EPA issued an 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 (EPA, 1993).

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.

4.3 Remedy Implementation

Remedy implementation is discussed in terms of (1) source control, (2) groundwater remediation and (3)

institutional control.

7

4.3.1 Source Control

On April 8, 1988, the Texas Water Commission (TWC) awarded the Superfund RA contract for OU-1 (the

first seven of the eight major components of the selected remedy) to Chemical Waste Management, Inc.

ENRAC-South (CWM). The TWC issued the notice to proceed to CWM on May 23, 1988, during the final

preconstruction conference, and CWM began RA construction on May 24, 1988.

CWM performed the contract work until October 7, 1988, when TWC issued a delay notice for shipping of

waste material. On October 21, 1988, the U.S. District Court for the Middle District of Alabama, Northern

Division, issued a temporary restraining order resulting from a lawsuit filed by the State of Alabama to

restrict out-of-state waste. This order was appealed and resolved by the courts by June 7, 1989. On

June 14, 1989, TWC issued a directive to CWM to resume performance of the contract by June 26, 1989,

after a delay of approximately nine months. Transport of site waste to the Emelle, Alabama, disposal

facility began on July 2, 1989, and continued through September 1989.

The RA for OU-1 was completed on September 28, 1990, when EPA approved the OU-1 RA report.

Deviations from the ROD were stated in the July 1993 ESD (EPA, 1993).

The ROD estimated that PCB concentrations in 22,500 cubic yards of soil would exceed the remedial

goal of 100 ppm PCBs. At the completion of the source control remedial construction in September 1989,

approximately 38,900 cubic yards of contaminated soil, a 73% exceedance over the ROD estimate, had

been disposed off-site. The volume of PCB-contaminated soil at the site was not discovered until the RA

was well underway, and soil tests indicated that more contaminated soil needed to be removed than was

foreseen based on the information developed during the RI.

In addition, one portion of the selected remedy was disposal of all on-site drums in an off-site facility.

However, during excavation, additional drums were found in three separate areas. Drums containing

polynuclear aromatic hydrocarbons (PAH) were found in the slurry wall excavation and also in the anchor

trench excavation. These drums were placed in the backfill beneath the permanent protective cap and

remain on-site. Other drums, whose contents were not identified, but were referred to as PCB-

contaminated material, were encountered during excavation in a third area and were also left on-site

beneath the permanent protective cap.

The final remedial cost of the source control RA was $20,624,984. All remedial objectives for OU-1

identified in the ROD were met by implementation of the remedy. The constructed OU-1 remedy is

operational and is performing in accordance with engineering specifications.

8

4.3.2 Groundwater Remediation

Groundwater in the 30-foot sand undergoing remediation is contained under a RCRA cap and is bounded

on all four sides by a slurry wall that is keyed into the aquitard clay that separates the shallow aquifer

from the deeper 100-foot sand unit (Corrigan, 1998). The slurry wall was completed in 1990, is an

average of 31-feet deep, and is composed of bentonite. On July 22, 1992, TWC awarded the RA contract

for OU-2, the eighth major component of the selected remedy, to Waste Abatement Technologies, Inc.

(WATEC). TWC issued a notice to proceed to WATEC on December 21, 1992. WATEC constructed 13

recovery and monitoring wells, 1,878 linear feet of aboveground supported piping, a treatment building

containing an activated carbon filtration system, six 30,000-gallon storage tanks, related foundation

facilities, service utilities, monitoring controls, asphalt paving, and fencing at the site. The recovery well

system consists of nine recovery wells completed in the 30-foot sand unit, and one recovery well

completed in the 100-foot sand unit (EPA 1998). Figure 6 is a site layout map showing the current

monitoring and recovery well locations. Table 3 lists the monitoring and recovery wells in use at the site

and their depth.

The RAO for TCE in on-site groundwater was established as 1.0 g/L in the ROD. However, this

remedial goal was later changed in the 1993 ESD to achieve the MCL of 5.0 g/L.

Construction of the groundwater recovery and treatment system was completed on April 22, 1993. The

treatment system was put into commission to verify that the discharge criteria could be met. By the end

of June 1993, seven approved discharge events had occurred, which indicated that the treatment system

was performing as designed. The treatment phase of the groundwater RA began on July 1, 1993. A

post-remediation O&M plan dated July 1993 established the O&M activities that were implemented at the

site.

Major groundwater recovery and treatment system modifications, including addition of a heavy-oil

separator, related piping changes, charcoal filter material replacement, and system cleaning, were

completed in September 1994. Groundwater recovery was performed in both the 30-foot sand unit and

the 100-foot sand unit. Toward the end of 1999, several of the recovery wells were out of service

because of lack of maintenance, and WATEC was repeatedly notified to remedy deficiencies and bring

the system back on-line. After numerous problems and periods of unscheduled system shutdowns,

WATEC’s contract was terminated in October 1999.

The current contractor, CB&I (formerly Shaw Environmental), was hired by the TCEQ in 2004 to rebuild

the system and maintain the site. Groundwater pumping was resumed in the 30-foot sand unit

intermittently in 2007, and on a regular basis in 2008. Groundwater pumping in the 100-foot sand unit

was not resumed because in the past the 100-foot sand unit was in compliance and pumping would

9

increase the potential for downward migration from the 30-foot sand unit. Currently, the operation

involves pumping groundwater from the 30-foot sand in order to maintain an inward gradient across the

barrier wall. The remedy is primarily containment with engineering control coupled with a lesser

remediation component (groundwater extraction and treatment). Although some NAPL is also being

recovered in the pumping/treatment process, the pumps in the recovery wells are positioned to avoid

pumping light nonaqueous phase liquid (LNAPL) or dense nonaqueous phase liquid (DNAPL). Nine new

recovery wells and pumps were installed in the 30-foot sand unit adjacent to the older recovery wells in

February 2011 because the older wells were not functioning properly.

There currently is no pumping and treating of groundwater from the 100-foot sand unit. A new pump has

recently been installed in recovery well RW-6, which is located in the 100-foot sand unit. There is

insufficient treatment plant capacity to pump and treat contaminated groundwater from both the 30-foot

and 100-foot sand units due to insufficient clean water storage tank capacity, which stores the treatment

plant effluent until sample analyses verify the water meets discharge criteria, after which the treated water

is discharged into the adjacent flood control channel.

4.3.3 Institutional Control

Institutional controls were mandated for the site in the 2007 ESD. Institutional controls have not yet been

implemented at the site.

4.3.4 Partial Deletion from the NPL

Effective May 8, 1997, EPA deleted a portion of the site from the NPL. The portion deleted was the

Source Control portion, which consisted of the first seven components of the eight remedial action

components of the ROD for the site. The partial deletion did not include the eighth ROD remedial action

component, the Ground Water portion of the Site. The Ground Water portion remains on the NPL with

remedial activities continuing for the groundwater system operation.

4.4 Operations and Maintenance

O&M is conducted at the site by TCEQ contractor CB&I. O&M at the site is summarized as follows:

Monthly reports are prepared that document gauging performed at the site, and results of clean

water effluent testing and discharge.

Monitor wells are gauged on a monthly basis to monitor the groundwater levels inside and outside

the slurry wall area. A slurry wall was constructed around the containment cell, and short-

duration pumping events are performed each month to ensure that groundwater elevations inside

the slurry wall are lower than elevations outside of the slurry wall.

10

Operate treatment system and recovery pumps within the containment cell. The purpose of

pumping is not to remove DNAPL, but to pump groundwater and reduce the groundwater level

within the slurry wall as described above.

The groundwater is processed through the treatment system, and clean water is stored in large

holding tanks. Samples of the clean water are analyzed by a laboratory, and if the samples pass

discharge criteria, then they are discharged to the Harris County Flood Control District drainage

ditch adjacent to the site.

A monthly O&M report is prepared which documents each gauging event, provides a

potentiometric map showing groundwater elevations inside and outside the slurry wall, and

provides a summary of the sample results and discharge.

The site is inspected monthly and the inspection report provided to TCEQ. The inspection

includes condition of the cap, the treatment plant, and the security of the site.

The grass on the cap is mowed as needed.

Groundwater sampling events over the years have ranged in frequency from quarterly, tri-annual, semi-

annual, and annual, depending upon instruction from TCEQ and related funding. Reporting is usually

comprised of several sampling events.

Currently, groundwater is pumped from nine recovery wells located in the 30-foot sand unit and treated in

order to maintain an inward gradient across the barrier wall. As such, this acts primarily as an

engineering control with a minor component of groundwater remediation. Groundwater is being pumped

from the recovery wells and treated before being discharged to the flood control channel. The pumps are

operated part of the month until the holding tanks are filled, and then shut down until discharge

confirmation samples show that the treated water meets surface discharge requirements.

The groundwater is treated by passing it through a sediment trap followed by two oil/water separators to

separate LNAPL, DNAPL, and water. The water then passes through a bag filter followed by a carbon

filter before being stored in the clean water storage tank where it is sampled and held until analytical

results are received. The process flow diagram of the treatment plant is shown in Figure 7. If the

analytical results show that the concentrations of contaminants are below acceptable discharge criteria,

the groundwater is discharged to the flood control channel. Otherwise, the groundwater is re-treated until

discharge criteria are met. The discharge criteria are established in Operations and Maintenance Manual

Process Treatment System (Shaw, 2006). Analytical results from samples taken from the clean water

storage tanks along with the discharge criteria are presented in Attachment 2.

11

Only one pumping/treatment/discharge event took place from July 2009 to February 2011, occurring in

July 2010. The O&M site manager for Geneva provided the following information on the sporadic

operation of the system from 2009 to 2011.

In June 2009 the clean water effluent discharge results indicated total dissolved solids (TDS)

concentrations slightly exceeding the discharge limits, with no other parameters exceeded. It is

unknown if the waters were discharged or simply held in the tanks for future action.

In July 2009 the clean water effluent discharge results revealed TDS and PCB concentrations

exceeding TDS and PCBs. At that time the waters were held in the clean water tanks pending

evaluation of the treatment system.

In August 2009 the granular activated carbon (GAC) was removed and replaced.

In July 2010 the effluent water from the June 2009 and July 2009 system run events was re-

processed through the treatment system, and all parameters were below the discharge criteria.

In August 2010 the effluent water was tested again, and the results revealed TDS and PCB

concentrations that exceeded discharge limits. The GAC tanks were subsequently tested, and it

was noted that the suction tubes within the GAC vessels were corroded from the internal tank

connections. After several months of negotiating with the tank manufacturer, the tanks were

repaired.

Replacement recovery wells were installed in February 2011.

On March 15, 2011, the August 2010 effluent was reprocessed through the treatment system,

and results (GVI-EFF-0311) exceeded discharge limits for PCBs. The elevated PCB

concentrations were attributed to the long shutdown period of the system and back-flushing of the

GAC units prior to treatment system start-up.

On March 31, 2011, the effluent water was reprocessed through the treatment system again, and

results (GVI-EFF-0311-2) revealed all constituents below discharge limits.

Shallow zone (the 30-foot sand unit) recovery wells RW-01 through RW-05, and RW-07 through RW-10

were replaced in February 2011 because the original recovery wells produced a large volume of silt which

eventually caused the recovery well pumps to fail, and an excessive amount of silt production in the

treatment plant. Silt production in the treatment plant caused extreme fouling of the silt knock-out vessel,

oil/water separators, and bag filters. Disposal of the silt, because it was impacted with PCBs, was

expensive. The new wells were installed to restore operation of the recovery wells/pumps, prevent

fouling of the treatment system components, and reduce waste disposal costs. Since the replacement of

these recovery wells, silt inflow has decreased and the pumping and treatment system are operating

normally. The new wells were installed adjacent to the original wells and the original recovery wells

remain in place and serve as piezometers.

12

Annual O&M costs are summarized in the table below. The annual O&M cost for 2011 was significantly

higher due to the installation of nine new recovery wells and pumps. Other than in 2011, the costs are

comparable to the costs in the last five-year review.

5 Progress Since Last Review This section reviews the protectiveness statement and issues and recommendations from the last Five-

Year Review, which was the third Five-Year Review for the Geneva site. The status of the

recommendations made in that report are also reviewed and discussed.

5.1 Protectiveness Statements from Last Review

The protectiveness statement from the last Five-Year Review is given as follows:

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. However, in order to remain

protective for the long term, the recommendations listed in Section 9.0 should be

implemented. Ongoing implementation of performance and compliance monitoring will

ensure that the migration of contamination continues to be restricted.

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.

Date Cost 9/2008 - 12/2008 $31,935

2009 $164,649 2010 $111,189 2011 $332,653 2012 $117,735

1/2013 - 4/2013 $71,315

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5.2 Status of Recommendations

The previous Five-Year Review report stated that the remedy continues to be protective of human health

and the environment in the short term. Six issues were identified that could potentially require further

actions and provided recommendations to ensure the remedy remain protective in the long term. A

summary of the issues and the re-evaluation and actions taken at the Geneva site since the previous

Five-Year Review are given below (EPA, 2008):

1. Issue: Groundwater elevations measurements were measured annually, except in 2007 when the

groundwater elevations were measured quarterly. This left large gaps in time between

measurements in which an inward gradient may not be maintained, as happened in 2006.

Actions: The frequency of the groundwater elevation measurements has increased to monthly over

the last two years; however, elevations were only gauged once from July 30, 2009 to February 23,

2011, the time period during which the groundwater recovery and treatment system was partially shut

down.

2. Issue: TCE concentrations in MW-26 were above the RAO.

Actions: Monitoring of TCE at MW-26 has continued over the past five years. There has only been

one exceedance of the TCE MCL since May 2008, a detection of 0.098 mg/L exceeded the MCL of

0.005 mg/L in the January 7, 2009 sampling.

3. Issue: Certain PCB isomers were detected in the last sampling event, January 2008.

Actions: Monitoring of PCB has continued over the past five years. The data review discussed in

Section 6.3 indicates PCB concentrations are increasing in the 100-foot sand unit.

4. Issue: No institutional controls are in place.

Actions: Although no institutional controls have been implemented, TCEQ is currently attempting to

identify the owners of the property prior to implementing institutional controls.

5. Issue: Several monitoring wells were not locked.

Actions: The June 25, 2013 site inspection found all monitoring wells to be unlocked.

6. Issue: Downward contamination from the 30-foot sand unit to the 100-foot sand unit is a concern.

Actions: Monitoring of the 100-foot sand unit has continued over the last five years. The data

review discussed in Section 6.3 indicates PCB concentrations are increasing in the 100-foot sand unit

and that downward migration from the 30-foot sand unit to the 100-foot sand unit is occurring.

6 Five-Year Review Process This Five-Year Review has been conducted in accordance with EPA’s Comprehensive Five-Year Review

Guidance (EPA, 2001). The Five-Year Review for this site was initiated by EPA which tasked the U.S.

Army Corps of Engineers to perform the technical components of the multidisciplinary review. The

scheduled completion date for this review is September 25, 2013; five years after completion of the last

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Five-Year Review. Interviews were conducted with relevant parties; a site inspection was conducted; and

applicable data and documentation covering the period of the review were evaluated. The findings of the

review are described in the following sections.

6.1 Community Involvement

A public notice announcing initiation of the Five-Year Review was published in the Houston Chronicle on

June 13, 2013. Upon signature, the Five-Year Review will be placed in the information repositories for

the site, including the M.D. Anderson Library at the University of Houston and the TCEQ office in Austin,

Texas. A notice will be published in the Houston Chronicle to summarize the findings of the review and

announce the availability of the report at the information repositories. A copy of the public notice

announcing the beginning of the five-year review is provided as Attachment 9 to this report.

6.2 Document Review

This Five-Year Review included a review of relevant site documents, including decision documents,

construction and implementation reports, quarterly and annual reports, and related monitoring data.

Documents that were reviewed are listed in Attachment 1.

6.3 Data Review

Compliance monitoring data collected as part of the operations and maintenance were reviewed as part

of this Five-Year Review. The data consist of groundwater quality data and groundwater level

measurements, and groundwater treatment plant effluent sampling data. A search for information on

water supply wells near Geneva was also conducted. Three groundwater samples were collected from

the monitoring wells shown in Figure 6 in both 2008 and 2011, two samples were collected in 2009, and

one sample collected in 2010, 2012 and 2013. Groundwater elevations were gauged six times in 2008,

nine times in 2009, once in 2010, eleven times in 2011, fourteen times in 2012, and seven times up to

June 5, 2013. The groundwater sampling reports, O&M event reports, and clean water storage tank

sampling reports from 2008 to 2013 were reviewed for this report.

6.3.1 Groundwater Elevations

Attachment 3 presents the groundwater elevations gauged in the monitoring and recovery wells since

2005. This data is collected to verify that gradient is being maintained into the area contained by the

slurry walls, the area of the highest concentrations of contaminants. The purpose of the groundwater

pumping and treating system is to induce an inward hydraulic gradient, preventing the contaminated

groundwater within the slurry walls from spreading. A representation of the groundwater potentiometric

maps created during this time and included in the groundwater monitoring reports are presented in

15

Figures 8 through 12 for the purpose of showing the hydraulic gradients in the shallow zone (30-foot

sand unit) and deep zone (100-foot sand unit) at the site.

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). Monitoring well MW-22, located at the northeast corner of the site, is

the only monitoring well installed in the 100-foot sand unit monitoring the northern portion of the site. It

appears that additional monitoring wells were not installed in the 100-foot sand unit along the northern

boundary of the site due to the belief that the gradient was to the west and southwest. Because the

current elevation gauging indicates the flow direction is to the north, 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.

The potentiometric surface maps for the shallow zone, as drawn, are not conclusive due to insufficient

data points. Also note that because the elevations within the slurry wall have been based on elevations

gauged in the recovery wells, which would be expected to be lower than the surrounding areas within the

slurry wall, these elevations would tend to overestimate the lowering of the water table within the slurry

walls, as shown on these maps.

Groundwater elevation data collected from the monitoring and recovery wells from January 2008 to June

2013 were plotted to evaluate the gradient around the perimeter of the slurry walls. Plots of the total head

at monitoring wells at the exterior of the western, northwestern, northeastern, and eastern perimeter of

the slurry wall were compared to total head gauged at nearby recovery wells in the interior of the area

contained by the slurry wall. Although there are no monitoring wells in the 30-foot sand unit along the

south side of the slurry wall, past investigations have indicated that the flow direction in this aquifer is to

the east-northeast, and it is very unlikely that contaminated groundwater contained in the slurry wall

would migrate to the south. Figures 13 through 16 show the head differential in the wells at these

locations. The monitoring wells are labeled MW- and the recovery wells are labeled RW-. Monitoring well

head greater than the recovery wells indicates a hydraulic gradient from outside the slurry wall to the

inside. These four plots indicate an inward gradient has been maintained most of the time during the last

five years. Although this information indicates an inward gradient has been maintained, from July 30,

2009 to February 23, 2011 only well gauging event took place, in July 2010. During this period the

recovery/treatment system was not operating as intended, with only one pumping/treatment/discharge

event occurring, in July 2010. When well gauging resumed on February 23, 2011, groundwater

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elevations in RW-10 were not gauged, and it is unknown if the inward gradient was being maintained in

this area at that time (Figure 15).

The 2008-2013 average total head for wells in the shallow and deep water bearing zones are presented

in the table below. The greatest head is in the highly contaminated 30-foot sand unit, and the hydraulic

gradient is from the 30-foot sand to the lower 100-foot sand and 250-foot sand units.

Well

Well Depth (feet below ground

surface)

Total Head Average 2008-2013

(feet NAVD88) Water Bearing Unit RW-2 44.0 20.7 30-foot sand unit

MW-102 112 10.8 100-foot sand unit MW-101 292 -133.4 250-foot sand unit MW-103 675 -136.5 600-foot sand unit MW-104 852 -91.9 700-foot sand unit

6.3.2 Groundwater Sampling Results

The analytical results from groundwater sampling for the monitoring wells collected from May 2008 to

January 2013 were evaluated in this review. All of the wells were sampled and analyzed for BTEX,

trichloroethene and daughter products, total dissolved solids (TDS), oil and grease (O&G), total organic

carbon (TOC), and PCBs. A summary of the data results is given in Attachment 4.

The monitoring well analytical results are summarized below. The ROD did not specify any RAOs for

groundwater except for TCE, which was established as 0.005 mg/L, the same as the MCL, in the 1993

ESD. The following is a summary of the detected analytes that exceeded the drinking water MCL during

the period May 2008 – January 2013. The Texas Risk Reduction Program (TRRP) rule establishes

protective concentration levels (PCLs) for site remediation. The TRRP Tier 1 PCLs are the default

cleanup standards in the program. Groundwater samples collected by TCEQ at Geneva are compared to

the TRRP Tier 1 residential groundwater PCLs for ingestion (GWGWING). For the contaminants being

analyzed for at the site, the Tier 1 GWGWING values are based on the MCLs. In the comparison below the

MCL values are equal to the TRRP Tier 1 GWGWING values.

Benzene (MCL 0.005 mg/L) – Exceedances of the MCL occurred only at MW-26 with a maximum

detection of 0.0089 mg/L.

Trichloroethene (MCL 0.005 mg/L) – Exceedances of the MCL occurred only at MW-26 with a maximum

detection of 0.098 mg/L.

Vinyl Chloride (MCL 0.002 mg/L) - Exceedances of the MCL occurred at MW-24 with a maximum

detection of 0.00845 mg/L, and MW-26 with a maximum concentration of 0.005 mg/L.

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Total PCBs (MCL 0.0005 mg/L) – Exceedances of the MCL occurred at MW-22 with a maximum

detection of 0.00053 mg/L, MW-24 with a maximum concentration of 0.0135 mg/L, MW-26 with a

maximum concentration of 0.077 mg/L, MW-101 with a maximum concentration of 0.0018 mg/L, MW-102

with a maximum concentration of 1.19 mg/L, and MW-104 with a maximum concentration of 0.0137 mg/L.

Trend analyses of the analytical results from the groundwater monitoring well samples were conducted

using sampling data from 2008-2013 at sampling locations and analytes with exceedances of the MCLs

using the Mann-Kendall trend test, using MAROS Version 2.2 (MAROS, 2006). Time-series plots of the

data were also developed. Table 4 presents a summary of the Mann-Kendall trend test results, and

Figures 17 through 26 present the time-series plots. No trend was determined for vinyl chloride for

monitoring wells MW-24 and MW-26, and for total PCBs for MW-24, MW-101 and MW-104. Decreasing

trends were determined for benzene for monitoring well MW-26, and for total PCBs and TCE for MW-26.

An increasing trend was determined for total PCBs at monitoring well MW-102. For total PCBs, MW-22

was determined to be probably decreasing. Although the Mann-Kendall test determined no trend for

PCBs for MW-24, a visual examination of the time-series plot shown in Figure 22 shows a significant

increase in concentrations in two of the last four samples compared to previous sample results, and PCB

concentrations are probably increasing at that location.

6.3.3 Groundwater Treatment Plant Effluent

Groundwater pumped from the recovery wells is treated and stored prior to discharge to the adjacent

Harris County flood control channel. The treatment plant effluent is stored in one of two 30,000 gallon

clean water storage tanks (CWST), which are sampled to verify the water meets the established

discharge criteria before being discharged. The discharge criteria are established in Operations and

Maintenance Manual Process Treatment System (Shaw, 2006). Analytical results from samples taken

from the clean water storage tanks along with the discharge criteria are presented in Attachment 2.

When the samples exceed the discharge criteria, the water is retreated and resampled and tested to

ensure the discharge criteria are met before being discharged. PCB exceeded the discharge criteria in

samples taken on June 21, 2009, July 27, 2009, March 15, 2011, and April 8, 2011. The discharge

criteria for grease and oil were exceeded in the May 15, 2009 sampling event. After the May 2009, and

March and April 2011 sampling events the water was re-treated and tested to verify the discharge criteria

were met before the water was discharged. Based on the description of O&M at the site provided by the

site O&M manager in Section 4.4, the effluent water from the June 21 and July 27, 2009 sample events

was retreated and resampled in July 2010, and met the discharge criteria.

The March 31, 2009 sample from the CWST exceeded the PCB discharge criteria. A valve on the CWST

failed and released this water into the secondary containment area holding the tanks. The monthly

sampling report stated that the water in the containment area was sampled on April 30, 2009 and that the

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sample results met the discharge criteria for PCB. This review was unable to confirm that the resampled

results met the discharge criteria because the analytical results were not provided. Copies of the

analytical reports should be retained to provide verification that discharge criteria are being met.

6.3.4 Water Supply Wells

Groundwater well databases were searched to determine the existence of known water wells installed

within one mile of the Geneva site. The Texas Water Development Board (TWDB) Groundwater

Database (GWDB) (TWDB, 2013a), the Submitted Driller’s Reports Database (SDRDB) available from

the TWDB web site (TWDB, 2013b), and the Harris-Galveston Subsidence District (HGSD) database

(HGSD, 2013) were searched.

The HGSD database only shows wells permitted for groundwater withdrawal located within the

subsidence district, which includes Harris County and the area around the Geneva site. Single-family

dwelling wells are excluded from the HGSD permitting requirements, along with windmills, monitoring

wells, leachate wells, extraction wells, injection wells and dewatering wells. The TWDB GWDB was

intended to gain representative information about aquifers in the state in order to support water planning

from the local to a more regional perspective. The wells in the database represent less than 10 percent

of the wells that actually exist in Texas. The Submitted Driller's Reports Database (SDRDB), in existence

since 2002, has captured up to an estimated 60 percent of the drill reports (and logs) that drillers are

required, by the State, to file upon completion of water well drilling since drillers began using the

application in 2002. These three databases do not present a complete listing of all wells in Harris County,

and there may be additional groundwater wells near the site not found by this database search.

A water well inventory of water wells with a one mile radius of the site was presented in the 1985 Site

Investigation (SI) (IT, 1985a). Of the wells found in the 1985 SI, all are either known to be inactive or

destroyed except for three domestic wells. Figure 27 shows all wells found in these three databases and

the three domestic wells in the SI well inventory located within one mile of Geneva. Attachment 5

presents summary tables of the database search results. Based on this search, 15 groundwater supply

wells within one-mile of the Geneva site were identified, although some of the wells are probably

duplicates, being listed in more than one database. Table 2 provides a summary of 15 water supply

wells.

Of the 15 water supply wells, the closest well is the domestic well located approximately 1000 feet south

of the slurry wall boundary, at 9310 Tallyho Road, reported to be 100 feet deep. Monitoring well MW-23

monitors groundwater in the 100-foot sand unit south of the site. There have been no exceedances of

MCLs at MW-23 since the detection of 0.0065J mg/L of PCB in January 2006, which indicates site

contaminates are not migrating to the south from the site in the 100-foot sand unit. Well 2332, the former

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Pilot Industries well located on the Geneva site no longer exists. All of the 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.

6.3.5 Conclusions

Review of available gauged groundwater elevations indicate that an inward gradient has been maintained

into the site for most of the time during the five year review period; however, elevation gauging has been

sporadic.

Contaminants in the monitoring wells in the 30-foot sand unit around the perimeter of the site are

nondetect or are decreasing, and there is little risk of contaminants migrating off site in the 30-foot sand

unit under the current site operations. MW-26 is located east of the eastern slurry wall and is the only

monitoring well in the 30-foot sand unit that detected contaminants above the MCL over the past five

years, with exceedances of the MCL for benzene, TCE, vinyl chloride and total PCB. Benzene, TCE and

total PCB are decreasing or non-detect at MW-26. Vinyl chloride concentrations increased from non-

detect in July 2010 and February 2011, to above the MCL in December 2011, and then decreased to non-

detect in 2012 and 2013.

Monitoring wells MW-22, MW-24 and MW-102 monitor the 100-foot sand unit and have all detected

exceedances of total PCB. MW-24 also had two vinyl chloride detections exceeding the MCL. MW-22 is

located near the northeast corner of the site and had only one slight exceedance of the PCB MCL. MW-

24 is located along the eastern boundary of the site, and has had a significant increase in PCB

concentrations in two of the last four samples compared to previous sample results, and PCB

concentrations are probably increasing at that location. PCB concentrations are increasing in MW-102,

located in the center of the site. Increasing concentrations of PCB in the 100-foot sand unit indicate

contaminants are migrating downward from the highly contaminated 30-foot sand unit.

PCB exceeded the MCL twice in the 292 foot deep MW-101 and twice in the 852 foot deep MW-104, but

based on the information currently available, there is not an increasing trend at these two wells. PCB has

not exceeded the MCL, but was detected in the 675 foot deep MW-103 in the April 2012 sampling event.

Monitoring wells MW-101, MW-102, MW-103 and MW-104 were installed in a cluster, being only five feet

apart at the surface. These wells were installed through the highly contaminated 30-foot sand unit in the

center of the site and within 20 feet of an abandoned oil well (IT, 1985b). During the site inspection, the

site manager pointed out rusted pipes and valves in the treatment plant had been replaced due to the

corrosive groundwater being treated. The deep wells (MW-101 through MW-104) have steel casing and

screens, as can be seen on the well schematics (Figures 28 through 31). The potential for degradation

of casings of these monitoring wells that are almost 30 years old should be investigated, to eliminate the

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potential concern of vertical contaminant migration due to well degradation. 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.

The labels on monitoring wells MW-101 and MW-102 have been switched at some point in the past since

the deep well schematics (Figures 28 and 29) were developed in 1985. The well names on the well

schematics do not match the current well labels, and the reported well depths for the current wells labeled

MW-101 through MW-102 are different than these schematics. The well depths given in Attachment 3

are the most current information, and were assumed to be correct in this review. The table below

presents the original 1985 label names and depths and the current 2013 reported depths. The well labels

for MW-103 and MW-104 may also have been switched, and the depths of these four deep wells should

be gauged to verify the reported depths are correct for each well.

Monitoring Well

1985 Deep Well Project Report Reported Depth

(feet below ground surface)

2013 Reported Depth (feet below ground

surface)

MW-101 112 292 MW-102 292 112 MW-103 675 675 MW-104 852 852

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.

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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.

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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


Party Responsible

Oversight Agency

Milestone Date


(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.


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


Party Responsible

Oversight Agency

Milestone Date


(Y/N)

Current Future

additional groundwater monitoring wells downgradient of MW-24.

7 Implement ICs as mandated in the 2007 ESD.


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.


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.


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


Party Responsible

Oversight Agency

Milestone Date


(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

Information Source

Well ID Owner Location Use Year

Drilled Depth

Feet bgs

Distance in feet and Direction from Geneva

Status

HGSD 1961 City of South

Houston 29.6644 -95.24

Public 1974 795 3200 ENE Inactive since 1983


Houston 29.6633 -95.2406

Public 1955 780 3000 ENE Inactive since 1983

HGSD 2332 Pilot

Industries 29.6611 -95.2497

Industrial 1971 286 Located on the

Geneva site No longer exists


Houston 29.6639 -95.2403

Public 1982 1200 3200 ENE Active

HGSD 7487 Compa

Development 29.6521 -95.2442

Unknown 1975 100 2800 SE Active

HGSD 10597 Sullair of Houston

29.6517 -95.255

Unknown 2009 300 2800 SW Active

TWDB 6522624 - 29.6678 -95.2558

Domestic 1986 286 2800 NW Unknown

TWDB 6523705 City of South

Houston 29.665 -95.2397

Public 1954 785 3500 ENE Unknown


Houston 29.6636 -95.2397



Houston 29.6644 -95.2394


SDR 32286 - 29.6694 -95.2494

Domestic 2004 85 3000 N Unknown

SDR 125948 Sullair 29.6517 -95.2642

Industrial 2007 361 4800 SW Unknown

1985 SI 1 Garner

Mobile Home Park

9443 Redford Ave

Domestic Unknown Unknown 4800 S Unknown

1985 SI 6 Fields Trailer

Park 8302 Hansen

Rd Domestic Unknown Unknown 3600 SE Unknown

1985 SI I - 9310 Tallyho

Rd Domestic Unknown 100 1000 S Unknown

Table 3 Depth of Recovery and Monitoring Wells

Well Depth

(feet below ground surface)

MW-08 99.6 MW-10 37 MW-11 34 MW-17 38 MW-22 138.6 MW-23 112 MW-24 110.9 MW-25 107.1 MW-26 35.3 MW-101 292 MW-102 112 MW-103 675 MW-104 852

RW-1 46.6 RW-2 44.0 RW-3 45.4 RW-4 45.3 RW-5 45.9 RW-6 119.2 RW-7 46.2 RW-8 41.6 RW-9 45.4

RW-10 47.3 RW-1R 45.0 RW-2R 44.0 RW-3R 43.0 RW-4R 44.0 RW-5R 44.0 RW-7R 43.0 RW-8R 42.0 RW-9R 45.0

RW-10R 44.0

Table 4

Mann-Kendall Trend Analysis Results 2008-2013

Well Water Bearing

Unit Contaminant

Number of

Samples

Number of

Detects Coefficient of Variation

Mann-Kendall Statistic

Confidence in Trend

All Samples "ND"?

Concentration Trend

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