Site Name: BRIO REFINING, INC
EPA ID: TXD980625453 EPA Region: 06 Metro Statistical Area: 3360
2501 DIXIE FARM ROAD, FRIENDSWOOD, TX 77089
Operable Unit:
ROD ID: EPA/ROD/R06-88/031 ROD Date: 03/31/88
Contaminant: ORGANICS; VOCS (DCA, TCE)
Keys: AIR MONITORING; ARARS; CAPPING; CLEAN WATER ACT; CONSOLIDATION; DEBRIS; DECONTAMINATION; DEED RESTRICTIONS; EXCAVATION; GROUND WATER; GROUND WATER MONITORING; GROUND WATER TREATMENT; INCINERATION; INSTITUTIONAL CONTROLS; MCLS; O&M; OFFSITE DISPOSAL; ONSITE TREATMENT; ORGANICS; PUBLICLY OWNED TREATMENT WORKS; SLUDGE; SOIL; STABILIZATION; STATE CRITERIA; TREATMENT TECHNOLOGY; VENTING; VOCS; WATER QUALITY CRITERIA
Abstract:
THE 58-ACRE BRIO REFINING SITE IS LOCATED IN HARRIS COUNTY, TEXAS, APPROXIMATELY 20 MILES SOUTHEAST OF HOUSTON. THE SITE IS BROKEN INTO TWO PARCELS, 49-ACRE BRIO NORTH AND 9-ACRE BRIO SOUTH, SEPARATED BY DRIVE FARM ROAD. THE SITE IS BORDERED BY MUD GULLY, A FLOOD CONTROL DITCH THAT DRAINS INTO CLEAR CREEK, DIXIE OIL PROCESSORS NPL SITE, FRIENDSWOOD OIL FIELD AND THE SOUTHBEND RESIDENTIAL SUBDIVISION. BETWEEN 1957 AND 1982 THE SITE REFINED CRUDE OIL AND STYRENE TARS TO PRODUCE TOLUENE, ETHYLBENZENE, AROMATIC SOLVENTS, NAPHTHALENE, DIESEL FUEL AND KEROSENE. VARIOUS OWNERS OF THE SITE STORED STYRENE TARS IN 24 OPEN PITS. OTHER WASTE PRODUCTS AND SLUDGES WERE STORED IN ABOVE GROUND TANKS. SITE INVESTIGATION INDICATE THAT BETWEEN 500,000-700,000 YD3 OF ONSITE SOIL HAVE MEASURABLE CONTAMINATION, AND THAT HIGH LEVELS OF VOCS EXIST IN GROUND WATER UNDERLYING THE SITE. PRIMARY CONTAMINANTS OF CONCERN AFFECTING THE SOIL AND GROUND WATER ARE VOCS INCLUDING 1,1-DICHLOROETHANE, 1,1,2-TRICHLOROETHANE, AND METHYLENE CHLORIDE; AND BASE/NEUTRAL ORGANIC COMPOUNDS INCLUDING PHENANTHRENE AND FLUORANTHENE. THE SELECTED REMEDIAL ACTION FOR THE BRIO REFINING SITE INCLUDES; EXCAVATION AND INCINERATION OR BIOLOGICAL TREATMENT OF ALL ONSITE SOILS, SLUDGES, AND LIQUIDS FOUND TO BE ABOVE ACTION LEVELS DEFINED IN THE ENDANGERMENT ASSESSMENT, WITH BACKFILLING OF ALL TREATED MATERIAL PASSING THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP). IF THE BRIO SITE TASK FORCE (PRPS) CAN SUCCESSFULLY DEMONSTRATE THE EFFECTIVENESS OF AQUEOUS-PHASE BIOLOGICAL TREATMENT IT WILL BE CONSIDERED, OTHERWISE, INCINERATION WILL BE SELECTED; EXCAVATION AND TREATMENT OF ALL VISUAL ONSITE SEEPS; EXCAVATION AND REMOVAL OF ALL OFFSITE SOILS CONTAMINATED ABOVE BACKGROUND LEVELS; FURTHER INVESTIGATION OF PIT G TO LOCATE SLUDGE OR CONTAMINATED SOIL UNDERLYING THE EXISTING ONSITE WASTEWATER TREATMENT IMPOUNDMENT; CONSOLIDATION AND DISPOSAL OF ALL INERT DEBRIS AND RUBBLE WITH ULTIMATE DISPOSITION TO BE DETERMINED DURING REMEDIAL DESIGN; DISPOSITION OF MUD GULLY, THE FLOOD CONTROL DITCH, TO BE DETERMINED DURING REMEDIAL DESIGN; INPLACE STABILIZATION OF WASTES EXISTING IN THE WASTEWATER TREATMENT IMPOUNDMENTS, BACKFILLING WITH DIKE MATERIALS, CAPPING, REGRADING AND VEGETATING TO IMPROVE RUNOFF, AND INSTALLATION OF A PACKAGE WASTEWATER TREATMENT SYSTEM OR ROUTE WASTEWATER TO A POTW; REMOVAL AND OFFSITE DISPOSAL OF TANK CONTENTS, AND DECONTAMINATION, DISMANTLING AND SELLING OR OFFSITE DISPOSAL OF TANKS; DISMANTLING OF ALL ONSITE PROCESS EQUIPMENT; MONITORING AMBIENT AIR; CONTROL OF AIR EMISSION FROM THE TREATMENT PROCESSES; VENTING WASTE ENCLOSURES TO AN EMISSION CONTROL DEVICE; TREATMENT OF GROUND WATER IN THE NUMEROUS SAND CHANNEL ZONE TO A LEVEL TO BE DETERMINED IN DESIGN; NATURAL ATTENUATION OF THE FIFTY-FOOT SAND AQUIFER WITH MONITORING TO ENSURE EFFECTIVENESS; REGRADING AND VEGETATING AREAS OUTSIDE EXCAVATION BOUNDARIES; CONSTRUCTION OF A STORMWATER TRANSMISSION SYSTEM DRAINING TO MUD GULLY; AND IMPOSITION OF DEED RESTRICTIONS AS NECESSARY. THE ESTIMATED PRESENT WORTH COST OF THIS REMEDIAL ACTION IS $23,308,000-$23,333,000 FOR BIOLOGICAL TREATMENT OR $22,458,000-$26,598,000 FOR INCINERATION BASED ON 62,900 YD3 OF TREATABLE MATERIAL.
Remedy:
UPON REVIEW OF THE INFORMATION CONTAINED IN THE ADMINISTRATIVE RECORD, IT IS EPA'S JUDGEMENT THAT LIMITED ACTION AND MONITORING AS DESCRIBED IN THE NO ACTION ALTERNATIVE OF THE BRIO REFINING/DIXIE OIL PROCESSORS FEASIBILITY STUDY APPEARS TO BEST SERVE BOTH STATUTORY AND SELECTION CRITERIA IN RELATION TO THE OTHER SOLUTIONS EVALUATED. A DETAILED DESCRIPTION OF THIS REMEDY AND AN EXPLANATION OF HOW IT MEETS STATUTORY REQUIREMENTS IS CONTAINED IN THE ATTACHED "SUMMARY OF REMEDIAL ALTERNATIVE SELECTION.". THIS ACTION WOULD INCLUDE:
* AFFECTED MATERIALS AND SOILS - THE BRIO/DOP ENDANGERMENT ASSESSMENT IDENTIFIED ACTION LEVELS BASED ON LIMITED EXPOSURE TO SITE CONTAMINANTS. THIS EXPOSURE SCENARIO RELIED HEAVILY ON THE USE OF SITE CONTROLS TO ENSURE A LIMITED PROBABILITY OF EXPOSURE TO THESE CONTAMINANTS. THE TERM SITE CONTROLS SHALL BE DEFINED BELOW, BUT SHALL INCLUDE RESTRICTED ACCESS THROUGH THE USE OF A SITE SECURITY FENCE. THE ENDANGERMENT ASSESSMENT DID NOT IDENTIFY ANY CONTAMINATED SOILS ON THE DOP SITE THAT EXCEED THE ACTION LEVELS DISCUSSED ABOVE. THEREFORE, EXCAVATION AND TREATMENT OF CONTAMINATED SOILS IS NOT NECESSARY AS LONG AS THE SITE CONTROLS ARE ENFORCED. HOWEVER, IF PROPER SITE CONTROLS ARE NOT ENSURED AND GREATER EXPOSURE RESULTS FROM ANY FUTURE ACTIVITIES, THEN THE ACTION LEVELS IDENTIFIED ABOVE NO LONGER WOULD APPLY AND TREATMENT OF CONTAMINATED SOILS MAY BE NECESSARY.
* SURFACE CONTAMINATION - THE SITE INVESTIGATIONS IDENTIFIED SURFACE STAINING THROUGHOUT THE DOP PROPERTY. THESE AREAS WILL BE ADDRESSED IN THE SITE MANAGEMENT PLAN DISCUSSED BELOW.
* OFF-SITE SOIL CONTAMINATION - ANY OFF-SITE SOIL CONTAMINATION FOUND DURING THE REMEDIAL INVESTIGATION OR DURING THE EXCAVATION OF AFFECTED MATERIALS AND SOILS SHALL BE REMOVED TO BACKGROUND LEVELS. THIS MAY REQUIRE THAT SPECIAL DETECTION LIMITS BE USED FOR SAMPLING EFFORTS AT THE SITE BOUNDARIES DURING THE REMEDIAL ACTION. THIS ACTIVITY WILL HAVE TO BE FURTHER DEFINED IN THE REMEDIAL DESIGN.
* DEBRIS AND RUBBLE - THERE IS MUCH INERT DEBRIS AND RUBBLE REMAINING ON THE SITE FROM PAST OPERATIONS. THIS MATERIAL MAY BE CONSOLIDATED AND THE ULTIMATE DISPOSITION OF THE MATERIAL DETERMINED DURING THE REMEDIAL DESIGN.
* MUD GULLY - CONTAMINANTS OBSERVED IN THIS FLOOD CONTROL DITCH AND THE "BOTTLE NECK" THAT EXISTS AS IT PASSES THE BRIO AND DOP SITES HAS BEEN A NOTED CONCERN OF THE EPA AS WELL AS LOCAL RESIDENTS AND THE HARRIS COUNTY FLOOD CONTROL DISTRICT. IT IS APPARENT THAT THESE PROBLEMS WILL HAVE TO BE CORRECTED AS PART OF ANY REMEDY THAT IS INSTITUTED AT THE SITE. INITIAL THOUGHTS WOULD SUGGEST A LOW-MAINTENANCE APPROACH TO RESOLVING THIS PROBLEM WHERE SOME TYPE OF PERFORMANCE STANDARD WOULD BE SET IN COOPERATION WITH THE HARRIS COUNTY FLOOD CONTROL DISTRICT. SUCH ACTIONS SHALL BE FURTHER DEFINED IN THE REMEDIAL DESIGN.
* WASTEWATER TREATMENT SYSTEM - THE EXISTING WASTEWATER TREATMENT SYSTEM MAY BE USED DURING REMEDIAL ACTION BUT WILL BE DISMANTLED AND REMOVED FROM THE SITE BY THE COMPLETION OF REMEDIAL ACTION.
* STORAGE TANKS AND DRUMS - REMOVE TANK CONTENTS, DECONTAMINATE TANKS, DISMANTLE TANKS; SELL OR TRANSPORT DISMANTLED TANKS TO AN EPA APPROVED DISPOSAL FACILITY; TRANSPORT TANK CONTENTS AND DRUMS TO AN EPA APPROVED OFF-SITE DISPOSAL FACILITY. IF TANKS ARE USED DURING REMEDIAL ACTIVITIES, THEY WILL BE DISMANTLED UPON COMPLETION.
* PROCESS EQUIPMENT - THE ENTIRE PROCESS FACILITY WILL BE DISMANTLED TO THE EXTENT THAT SOME OF THE EXISTING FACILITY MAY BE USED DURING REMEDIAL ACTIVITIES. IF THEY ARE USED DURING REMEDIAL ACTION, THE STRUCTURES WILL BE DISMANTLED UPON COMPLETION OF THESE ACTIVITIES.
* MONITORING AND CONTROL OF MIGRATION PATHWAYS - AMBIENT AIR SAMPLING ON A SEMI-ANNUAL BASIS; CONTROL AIR EMISSIONS FROM TREATMENT PROCESSES (IF NECESSARY); EXCAVATE IN ENCLOSURES (IF NECESSARY) AND VENT THE ENCLOSURE TO AN EMISSION CONTROL DEVICE; ELIMINATE OR CONTROL RAINFALL ON CONSTRUCTION AREAS; SAMPLE AND MONITOR MUD GULLY SEDIMENTS; MONITOR THE GROUNDWATER IN THE NUMEROUS SAND CHANNEL ZONE AND FIFTY-FOOT SAND FOR A TIMEFRAME TO BE DEFINED IN THE REMEDIAL DESIGN; AND MONITORING ACTIVITIES WILL BE UTILIZED TO DETERMINE THE EFFECTIVENESS OF THE ACTIONS TO BE IMPLEMENTED AND SHALL BE DETAILED IN THE OPERATION AND MAINTENANCE PLAN OF THE REMEDIAL DESIGN. THIS SAME DATA WILL BE EVALUATED DURING THE AGENCY'S 5-YEAR REVIEW, IN ACCORDANCE WITH SARA SECTION 121(C), TO DETERMINE IF ANY CORRECTIVE ACTION IS NECESSARY.
* SITE MANAGEMENT PLAN - THE ENTIRE DOP SITE WILL BE REGRADED AND VEGETATED TO PROMOTE DRAINAGE AND MINIMIZE INFILTRATION. ALL REGRADED AREAS WILL BE COVERED WITH 6 INCHES OF TOPSOIL, IF NECESSARY, TO PROMOTE VEGETATIVE GROWTH. TO THE MAXIMUM EXTENT PRACTICABLE, THE AESTHETICS OF THE SITE (UPON COMPLETION OF THE REMEDY) SHALL BE ENHANCED BY UTILIZING CREATIVE DESIGN AND LANDSCAPING TECHNIQUES WITH INPUT FROM THE LOCAL RESIDENTS.
SITE CONTROL - THIS REMEDIAL ACTION IS BASED ON PERMANENT SITE CONTROL, IMPOSITION OF NECESSARY DEED NOTICES AND RESTRICTIONS (IF POSSIBLE), AND RESTRICTION OF ACCESS TO THE SITE BY USE OF A FENCE OR SIMILAR BARRIER.