Waste Pits remediation schedule extended, disposal and classification of waste questioned
By Gilbert Hoffman
The San Jacinto River Coalition, and THEA have learned that the time line for remediation and removal of the Waste Pits in the river will take considerably more time than originally thought, due to a number of factors.
Pre-Design Investigation, or PDI, discovered that the depth of the waste to be removed was much greater than the original 12 feet. In some places in the Northern Impoundment it was as deep as 25 feet. The significance of this meant that more material would have to be removed, and more water infiltrating from the river would have to be treated. The original time line had been to complete the project in 2 and one-half years, and now it looks like the schedule will be seven years. The Final Design plan called for one year of preparation to procure contractors and materials, 5 years to remove the waste material (the site would be divided into five zones, each separated from the others, and taking a year to remediate) and a year to mobilize.
However, in September THEA learned that the EPA had granted the PRP consultant’s request for additional time for engineering, due to the increased scope and depth of the waste. EPA allowed them to take an additional 160 days to prepare their Final Design plan. The Pre-Final Design for the Northern Impoundment is now due in April 2021. The Pre-Final Design for the Southern Impoundment was submitted in September 2020. The Final Design for the Southern Impoundment was due in November 2020. The Final Design for the Northern Impoundment is due this year, in June 2021.
A number of factors are controlling the extended schedule. One is that the EPA has agreed not to work on the site during extreme weather conditions, such as hurricanes. But on analysis, it was decided to also avoid the rainy season when floods are historically recorded. That only leaves about six months each year to work unrestricted. Other factors included access to the site from I-10, and TXDOT’s plan to replace the bridge and highway over the river, starting sometime in 2024.
THEA is concerned about the extended schedule, because it exposes the site to more possible breaches of the containment cap. An example is just last December, when a tugboat named the M/V TYLER T sank on the morning of December 22 at the Cheryl K Marine San Jacinto River Fleet docks, near the Sand Separation area and the waste pits. The oil spill was investigated by Harris County Pollution Control and the Coast Guard. Although the pits were not damaged, the potential for this was illustrated in the accident.
The PRP (Potential Responsible Parties) and their consultant have a TWG (Technical Work Group) that meets regularly to coordinate their plan with other entities. These include TXDOT, US Coast Guard, Corps of Engineers, and TCEQ. However, Jackie Medcalf of THEA believes it should have more local representation, including Harris County Pollution Control and Port of Houston. Although these groups are advised of plans, they do not participate “at the table.”
The Southern Impoundment is not considered to have the extreme hazardous waste found in the Northern Impoundment, and will be remediated only to a clean-up level of 240 nanograms per kilogram, as the Northern Impoundment goal is 30 ng/kg. The map accompanying the 30% Design shows excavation sites varying from 4 feet to 10 feet in depth.
Soil borings in the PDI phase indicated concentrations of toxins higher than originally thought, and the issue has arisen of where this waste will be sent for disposal, and whether it can be safely disposed of. Medcalf believes that the classification proposed, non-hazardous Type II, allows it to go to Household Waste landfills that are not appropriate for the danger. These landfills, usually in Louisiana, only monitor the waste for 30 years, although dioxin has a life of 700 years. EPA asked the PRP to retest the waste, but have accepted the current classification after the retest. However, their remedial project manager, Gary Baumgarten, indicated to THEA that they might retest the material and water during the remediation process.
All of this planning and design is still subject to a final agreement with the PRP to pay for the remediation and go ahead with the work. This is not concluded however, and could extend the process even further. In the meantime, THEA has broadened their interest in environmentally contaminated sites, and it proactively examining and speaking out for remediation of the Jones Road Superfund site in Cypress, and the Fifth Ward Cancer Cluster in Houston.
The next meetings of SJRC and THEA are scheduled for March 9, a Town Hall about all of these sites, and March 23 a San Jacinto River Coalition community meeting. They will be conducted by Zoom; contact TxHEA.org if you wish to participate.
