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PUBLIC HEALTH ASSESSMENT ADDENDUM

FRENCH LIMITED
CROSBY, HARRIS COUNTY, TEXAS


SUMMARY

The French Limited Site is a former petroleum based wastedisposal site located in Harris County about 20 miles northeastof Houston, Texas. Although there is evidence of past exposureto site contaminants,the site currently poses no apparent publichealth hazard.

Persons who may have been exposed in the past include residentsand on-site workers who may have inhaled volatile organiccompounds during the time the site was active and persons who atefish contaminated with polychlorinated biphenyls. Due to thelack of historical ambientair data from when the site wasactive, we were unable to confirm or quantify past inhalationexposures. We do not know if the fish in the local bodies ofwater are still contaminated. However, assuming that they are,we estimate that continued ingestion of these fish couldresultin a low increased lifetime risk of developing cancer.

Since part of the remediation process involves aerating thelagoon, future inhalation exposure to volatile organic compoundsthrough inhalation is possible. Modeling data, based onfenceline measurements taken during lagoon aeration, were used toestimate contaminant concentrations in eachof the surroundingcommunities. The ambient air concentrations predicted by themodel, for each of the communities, are upper-bound estimates andgreatly overestimate actual ambient air levels. Based on thepredicted values we estimate that the residents in thesurrounding communities have no apparent increased lifetime riskof developing cancer from exposure to these contaminants. Additionally, a new procedure for aerating the lagoon has beendeveloped which will reduce the release of contaminants into theair even further.

During the course of the investigation we noted that water fromresidential wells in the Riverdale Subdivision contained lead atlevels above recently revised health standards. Elevated levelsof coliform bacteria were also present. Although the source ofthe lead contamination is not known and is probably not relatedto the site, it may present a public health hazard. Since thesedata were over five years old we were unable to determine thecurrent public health significance of these findings. However,chronic exposure to leadcould pose a public health threat sincethere is no longer thought to be a dose level below which effects from lead will not be seen.

Citizens raised several questions concerning health effects fromexposure to site-related contaminants. Detailed answers to thesequestions appear in the Public Health Implications section ofthis public health assessment.

The Agency for Toxic Substances and Disease Registry(ATSDR)has made recommendations to (1) resample the residential wells todetermine if a current health risk exists, (2) implement controlsto limit the release of contaminants into the ambient air duringremediation, (3) resample fish and implement controls to preventfishing in certain bodies of water if necessary, and (4) collectambient air samples from the communities during remediation.


BACKGROUND

In cooperation with the Agency for Toxic Substances and DiseaseRegistry (ATSDR), theTexas Department of Health (TDH) willevaluate the public health significance of this site. Morespecifically, ATSDR and TDH will determine whether health effectsare possible and will recommend actions to reduce or preventpossible health effects. ATSDR, a Federal agency within theDepartment of Health and Human Services, is authorized by theComprehensive Environmental Response, Compensation, and LiabilityAct of 1980 (CERCLA) to conducthealth assessments at hazardouswaste sites.

A. SITE DESCRIPTION AND HISTORY

The 22.5-acre French Limited site, a former petroleum based wastedisposal site, is located in Harris County about 20 milesnortheast of Houston, approximately 2 miles southwest of Crosby,Texas, and 17 miles northwest of Galveston Bay (Figure 1). Thesite is bordered by Gulf Pump Road to the south, U.S. Highway 90to the northwest, and by a privately owned 17.96-acre tract tothe east. Sikes Disposal Pits, also a NationalPriorities List(NPL) site, is located approximately 0.5 miles to the west acrossU.S. Highway 90. The San Jacinto River is located approximatelyone-mile to the west of the site along the western most border ofthe Sikes Disposal Pits site. Figure 2 shows the site andsurrounding communities.

The site contains an approximately 8-acre unlined main waste pitcompletely surrounded by an earthen dike. A smaller waste pitlies east of the main waste pit, and sloughs and swampy areas arelocated west, north, and south. The entire French Limited sitelies approximately 10 feet above mean sea level (MSL), entirelywithin the 100-year floodplain of the San Jacinto River (28feet). The site has been completely flooded at least four timessince 1969. During one of these flood events, the dikesurrounding the main waste pit was overtopped and breached, andcontaminated sludges were discharged into an adjacent slough. Inan Immediate RemovalAction the United States EnvironmentalProtection Agency (EPA) repaired the dike and pumped the majorityof the discharged sludges back into the pit. The floatingportion of the sludge was removed and disposed of. See Figure 3for the important features on and around the site.

The site, which was originally privately owned, began operatingas a commercial waste disposal site in 1965. In 1967, FrenchLimited of Houston, who had previously used the Sikes DisposalPits as their primary disposal site, purchased what is currentlythe French Limited site. During the period between 1965 and 1967(when active operation ceased) approximately 300,000 cubic yardsof industrial wastes were deposited on the site. The majority ofthe wastes were deposited in the unlined main waste pit; however,some wastes were stored upon arrival in large tanks and burned inan open pit process.

The site was first brought to the attention of the Texas WaterPollution Control Board (TWPCB) and Harris County when arearesidents registered complaints of odors and burning wastes. In1967, the TWPCB requested that the Texas Water Development Board(TWDB) investigate the site for possible ground-watercontamination. The TWDB concluded that the contents of the pitwould contaminate the groundwater if allowed to remain on site.

In 1967, the TWDB required French Limited to apply for a wastecontrol permit. After 3 years of negotiations, French Limitedwas granted a permit with special provisions one of which was theinstallation of an impermeable liner to prevent seepage from thepit. After extensive public hearings and legal proceedings, thepermit was cancelled in 1971 for failure to comply with thespecial provisions. In 1973 the state sued French Limited fornoncompliance and was deeded the disposal site as part of thesettlement.

Between 1971, when active operations ceased, and 1981, when thesite was added to the National Priorities List (NPL), numeroussamples had been collected from within the main waste pit (waterand sludge); from surface waters and sediments outside the pit;from ground waters on the site; and from local wells. Analysisof those samples indicated the presence of priority pollutantswithin the pit, in surface areas adjacent to the pit, and inwater from on-site monitoring wells.

In early 1981, a Field Investigation Team (FIT) determined that ahigh potential for ground-water pollution existed. That sameyear, the state of Texas applied for Federal assistance toconduct a full investigation of the site. On April 29, 1982 theEPA signed a cooperative agreement with the Texas Department ofWater Resources (TDWR), predecessor of the Texas Water Commission(TWC) to conduct a Remedial Investigation (RI)/Feasibility Study(FS) for the French Limited site.

In January 1983, TDWR contracted with Lockwood, Andrews, andNewman, Inc. (LAN), to conduct a Remedial Investigation (RI) atthe site (1). The initial phase of the RI was performed in April1983. A supplemental phase of the RI was performed in November1983. In 1986, a group of Potentially Responsible Parties, theFrench Limited Task Group (FLTG), conducted a Field Investigationand Supplemental Remedial Investigation Report (2). Results fromthese studies were utilized in the Feasibility Study andselection of the remedy. A Record of Decision was signed in 1988(3). The remedy, which was ongoing during the writing of this report, was to include:

  1. In situ biological treatment of sludges and contaminated soils in the lagoon on site.
  2. Recovery and treatment of contaminated ground water.
  3. Treatment of the surface water from the lagoon.
  4. Backfilling of the remaining lagoon volume with clean soil.
  5. Post-closure monitoring of the upper and lower aquifers for a period of 30 years.

The original Health Assessment (4) for the French Limited NPLsite, dated October 29, 1986, consisted of a short review of theDraft Endangerment Assessment (5). The review recommended thedevelopment of a "random trespass" exposure scenario in whichcontact with site soil contaminants would not be on a dailybasis. This Addendum contains a more complete analysis of thepublic health implications of the site and incorporates datacollected subsequent to the original Health Assessment. It alsoaddresses community concerns and makes recommendations specificto the findings.

B. SITE VISIT

On July 16, 1991, Texas Department of Health staff members Dr.John F. Villanacci and Dr. Nicholas J. Giardino visited theFrench Limited site. During the site visit, both the EPA and theFrench Limited Task Group (FLTG) project site managers wereavailable to answer questions and conduct a tour of the area. Atotal of six hours was spent in the French Limited site vicinity,three hours on site and three hours off site.

A six-foot chain-link fence, capped with barbed wire, surroundedthe entire site. A security guard was stationed in a guard shackat the entrance to the site. There were numerous workers on siteconstructing the remediation facilities. All workers werewearing standard construction and protective gear which includedhard hats and eye protection. Across the entrance from the guardshack was a cinder block building which contained offices, aconference room, and a break area. Another building of similarconstruction was located adjacent to this building and containedrest rooms, shower and decontamination facilities.

The entire main waste area was surrounded by a 20-foot high sheetpiling flood-control wall. This wall was constructed fromindividual interlocking corrugated metal units driven through theupper layer of sand into clay at a depth of approximately 40feet. There was a single entrance through this wall. We weretold by the project site manager that the wall was constructed tobe higher than the 100-year flood level and would protect thewaste pit and remediation activities from possible flooding. During our visit, a wall of similar design was being constructedthrough the middle of the waste pit. The workers wereconstructing the wall while standing on barges located in thelagoon.

Directly adjacent to the waste pit, outside the metal wall, awaste water treatment plant was in the initial stages ofconstruction. Across Gulf Pump Road, to the south of the site, asix-foot high chain-link fence, capped with barbed wire, wasbeing erected around Murphy's Lake. Murphy's Lake is a five-acrebody of water that was formerly an excavated sand pit. Monitoring wells were being installed within the newly fencedarea.

According to FLTG personnel, the contamination of the upperaquifer had spread to an area encompassing approximately one-half of Murphy's lake. The contaminated water was to bedrawn back through the wells, treated in the waste watertreatment plant, then discharged into the San Jacinto River. Aneight-inch diameter pipe had been installed along U.S. 90 to theSan Jacinto River. The discharge area was well concealed andlocated on a steep incline. It did not appear to pose anyhazard.

Immediately to the west, adjacent to Murphy's Lake, we saw theold Harris County Landfill. This area was well fenced along GulfPump Road.

The area surrounding the site was very swampy with small andlarge bodies of water all around. Immediately to the west wasthe Sikes Disposal Pits NPL site upon which an incinerationfacility was being constructed. Also west of the site was anactive marina.

During the site visit we visited three of the subdivisionsimmediately surrounding the site, Riverdale to the south, Roggeto the northeast, and Sleepytime to the east (Figure 2). Theclosest residence to the site, a single family home wasapproximately 1,000 feet to the southwest of the site. We saw aman fishing in Riverdale Lake, a small body of waterapproximately 1,500 feet to the southwest. We were told byresidents that fishing was common. Residents also told us thatprior to the remediation process fishing was also common inMurphy's Lake and that prior to remediation the site wasaccessible to the residents and the children. We saw children ofall ages in all three of the subdivisions.

C. DEMOGRAPHICS, LAND USE, ANDNATURAL RESOURCE USE

Demographics

Several small communities, including Riverdale, Barrett, MagnoliaGardens, and Crosby, are within approximately three miles of thesite. The Riverdale Community lies southwest of the site andconsists of large lots with residential housing. In 1985,Riverdale had a reported population of about 100 people.

Approximately 7,613 persons live in the Crosby-Barrett area.According to preliminary 1990 Census data 4,863 persons live inthe townships: 1,811 persons in 731 homes in the City of Crosby;and 3,052 persons in 1,077 homes in the City of Barrett. Withinthe area immediately surrounding the site, in the same censustracts as the townships (tracts 252,253,255, and 258), there are2,750 persons in 1,074 homes (Figure 2). The racial makeup ofthe Crosby-Barrett area is 54 percent white and 46 percentnon-white. Six percent of these two groups are of hispanicorigin. The percentage of non-white persons in the City ofBarrett (97%) is higher than in the City of Crosby (17%). Twenty-four percent of the population in the above mentionedareas is under 18 years of age.

Land Use

The French Limited NPL site is located in the less developedeastern portion of Harris County. No significant acreage ofagricultural land is located within a one-mile radius of thesite; however, pasture and cropland are found outside the floodplain on both sides of the San Jacinto river at greater distancesfrom the site.

The area immediately surrounding the site is primarilyundeveloped, densely wooded land with large intermittent sandpits and swampy areas. The property adjacent to the Riverdalesubdivision, immediately south of the western most portion of thesite, was used as a landfill by Harris County in the late 1960'sand subsequently as a pipe storage yard. We were unable to gainaccess to this area during our site visit. Gulf Pump Road, whichborders the site on the south, previously showed evidence ofillegal garbage dumping in roadside ditches.

Approximately two miles west of the site, on the western bank ofthe San Jacinto River, is the Champion Paper Company Plant. There are also some sand mining operations along the San JacintoRiver and its tributaries. Some commercial timber and mineralexploration operations have been conducted north of the site inthe past.

Natural Resource Use

The Chicot aquifer, which underlies the site, provides freshwater to the majority of the wells in the area. In the sitearea, the Chicot aquifer consists of an upper aquifer and a loweraquifer hydraulically separated by approximately 80 feet of clay. The upper aquifer extends to a maximum depth of approximately 55feet. The lower aquifer extends to about 500 feet. The deeperEvangeline aquifer, also underlying the site, is the mostimportant source of fresh ground water for the Houstonmetropolitan area. The upper aquifer consists of two distinctand separate channels, one underlying the French Limited site andthe other underlying Riverdale.

The 1985 RI identified 70 water production wells withinapproximately three miles of the site. Thirty of those wellswere located in the Riverdale subdivision immediately southwestof the site. The Riverdale wells are primarily shallow (24 to300 feet), small diameter (two- to four-inch casings), domesticwater supply wells. See Figure 4 for the location of the wells.

The climate in Harris County is warm and humid with an average of48.18 inches of rain each year. Although the monthly rainfall iswell distributed, a maximum 24-hour rainfall over 15 inches hasbeen recorded (6). Rain falling on the site leaves by a combination of evaporation, infiltration, and overland flow toadjacent water bodies.

Surface water runoff from the French site occurs during floodingor heavy rainfall. The general surface water flow pattern in thearea is southwest toward the San Jacinto River (Figure 5). Thedrainage of the site and adjacent areas is poor and generallydominated by man-made features such as roads, ditches, culverts,berms, pits, and garbage dumps or fill areas. Prior to theerection of the perimeter wall, the main and east pits werebermed and had no regular flowing outlets. The main waste pitdid have an overflow which discharged directly into the fishinghole located under U.S. Highway 90. The overflow was installedto prevent overtopping of the berms around the pit during heavyrainfall. The fishing hole drains northward and then west alongthe north side of U.S. Highway 90 eventually reaching the SanJacinto River.

Water from the San Jacinto River flows into Galveston Bay, whichis located about 16 miles downstream. The commercial fishingindustry is substantial in the lower reaches of the San JacintoRiver and throughout Galveston Bay. Recreational fishing in theSan Jacinto River, the Jackson Bayou, and other small bodies ofwater near the site, is known to occur but the amount andfrequency of this fishing has not been determined. The varietyof sport fish include bass, bream, and catfish.

In addition to sport fishing, the surrounding area has been usedfor multiple purposes. These include sand pit operations, boatlaunching, water skiing, and swimming. Off-road vehicle eventshave also been held in this vicinity.

D. HEALTH OUTCOME DATA

On June 20, 1991 Harris County Health Department officials werecontacted about the availability of any health data fromresidents living in the vicinity of the French Limited site. Other than routinely collected birth and death data, theyreported no additional health outcome data associated with thesite. This type of data is not retrievable for Crosby andBarrett.

The Texas Department of Health Cancer Registry Division maintainsincidence and mortality data for Cancer in Texas. After meetingwith representatives from the Cancer Registry Division, wedecided that we could not use the available cancer data for thefollowing reasons: (1) incidence data for Texas Public HealthRegion 4, in which this site is located, are incomplete and wouldunderestimate the true incidence rates; (2) cancer mortality dataare not available for cities with less than 2,500 persons, thuswe would be unable to obtain data specific to the Crosby andBarrett areas. Hospital discharge data were also unavailable.

No investigations associated with this site are listed in theTexas Department of Health, Division of Epidemiology,Epidemiology Investigation Index file. This file coversinvestigations conducted from the 1960's to the present time.


COMMUNITYHEALTH CONCERNS

In an initial effort to determine community health concerns, wecontacted the EPA, the TWC, TDH Region 4, and the Harris CountyHealth Department. The EPA was the only agency which has recordsthat included community health concerns associated with the site. The information in the EPA files included newspaper articles,telephone log sheets, and records of communication. Additionally, during our site visit we spoke with representativesof the Crosby Chamber of Commerce and went door to door to speakwith a sample of residents from the surrounding communities toobtain health concerns. The individual residents to whom wespoke lived in the Riverdale, Rogge, and Sleepytime subdivisionsall within a 3/4-mile radius of the site. All the residents thatwe spoke to were given a brief explanation of the purpose of ourvisit. Health related concerns were obtained for both the Frenchand Sikes NPL sites. Concerns were included in the healthassessments for both sites unless the citizen specificallyreferred to one site or it was obvious that the concern wasspecific to one site. The following health-related concernswere obtained for the French site:

  1. Could the site be the cause of unexplained skinrashes?
  2. Will there be odors generated during the re-mediationprocess?
  3. Will water from the site be dumped into theSan Jacinto River and will it contaminate thefish?
  4. Could deaths from respiratory disease haveresulted from exposure to site contaminants?
  5. Could the site be responsible for mouthulcers, upper respiratory infections, and earinfections in a two year old child?
  6. Could exposure to site contaminants beresponsible for the slow development of a twoyear old child, development being defined theinability to talk yet?
  7. Is the water safe to drink?
  8. Can the site be responsible for the poorquality of water in Barrett?
  9. Can the site be responsible for the largeamount of cancer that residents havereportedly observed in people living in thearea?
  10. Can the site be responsible for the wholebody swelling experienced by a resident afterdrinking water from Barrett?
  11. Should they be concerned about havingpreviously eating fish from the lakes aroundthe site?
  12. Should they be concerned if their childrenused to play on the site before it wasfenced?


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