HRS Documentation Record i US Oil Recovery

TXN000607093

HAZARD RANKING SYSTEM (HRS)

DOCUMENTATION RECORD - REVIEW COVER SHEET

Name of Site: US Oil Recovery

EPA ID No.: TXN000607093

Contact Persons

Site Investigation: Brenda Nixon Cook, NPL Coordinator, EPA Reg.6

(Name) (Telephone)

(214) 665-7436

Documentation Record: Brenda Nixon Cook, NPL Coordinator, EPA Reg.6

(Name) (Telephone)

(214) 665-7436

Pathways, Components, or Threats Not Scored

1) Ground Water Pathway: The ground water migration pathway has not been scored because an 

observed release to the ground water pathway has not been documented and there are no 

analytical data to support a release. Based on information available at this time, evaluation of 

the ground water migration pathway would not significantly affect the listing decision (Ref. 1, 

Sec. 2.2.3).

2) Soil Exposure Pathway: The soil exposure pathway has not been scored because observed

contamination has not been documented on or within 200 feet of soil pathway targets. Based 

on information available at this time, evaluation of the soil exposure pathway would not 

significantly affect the listing decision (Ref. 1, Sec. 2.2.3).

3) Air Pathway: The air migration pathway has not been scored because an observed release to the 

air migration pathway has not been documented and there are no analytical data to support a 

release. Based on information available at this time, evaluation of the air migration pathway 

would not significantly affect the listing decision (Ref. 1, Sec. 2.2.3).

4) Surface Water Pathway: The Surface Water Pathway has been scored for the Human Food 

Chain Threat and Environmental Threat. However, the Drinking Water threat has not been 

scored. Based on information available at this time, evaluation of the drinking water threat 

would not significantly affect the listing decision (Ref. 1, Sec. 2.2.3). 
HRS Documentation Record 2 US Oil Recovery

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HRS DOCUMENTATION RECORD

Name of Site: US Oil Recovery

Site Spill Identifier No.: A6X7

CERCLIS Site ID No.: TXN000607093

EPA Region: 6

Date Prepared: September 2011

Street Address of Site: 400 and 200 N. Richey Street*

City, County, and State: Pasadena, Harris County, Texas 77506*

General Location

within the State: The site is located in the City of Pasadena, Harris County, Texas. 

Pasadena is located in southeast Texas (Ref. 3, p. 1). 

Topographic Map(s): The following U.S. Geological Survey (USGS) 7.5-minute 

topographic series map was used in locating the site: Pasadena, Texas 

(1995) (Ref. 3, p. 1).

Latitude/Longitude (400 N. Richey Street)*: 29° 43’ 6.2” N, 95° 13’ 17.5” W 

Latitude/Longitude (200 N. Richey Street)*: 29° 42’ 53.05” N, 95° 13’ 11.07” W

Latitude and Longitude coordinates were measured from the northeast corner of the surface 

impoundment at 400 N. Richey Street and at the middle of the Trickling Filter on the west side of 200 

N. Richey Street and were determined using a scaled topographic map and GIS software (Ref. 4, pp. 1-

2).

*The street address, coordinates, and contaminant locations presented in this HRS documentation record identify the general area in 

which the site is located. They represent one or more locations EPA considers to be part of the site based on the screening information 

EPA used to evaluate the site for NPL listing. EPA lists national priorities among the known "releases or threatened releases" of 

hazardous substances; thus, the focus is on the release, not precisely delineated boundaries. A site is defined as where a hazardous 

substance has been "deposited, stored, placed, or otherwise come to be located." Generally, HRS scoring and the subsequent listing of a 

release merely represent the initial determination that a certain area may need to be addressed under CERCLA. Accordingly, EPA 

contemplates that the preliminary description of property boundaries at the time of scoring will be refined as more information is 

developed as to where the contamination has come to be located.

Scores

Air Pathway Not Scored

Ground Water Pathway Not Scored

Soil Exposure Pathway Not Scored

Surface Water Pathway 100.00

HRS SITE SCORE 50.00
HRS Documentation Record 3 US Oil Recovery

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NOTES TO THE READER

1. The following rule applies when citing references in this documentation record:

Tracking numbers are assigned by the region to every page of every reference. The tracking 

number consists of the reference number followed by the page number within that reference. A 

tracking number has a two-digit number followed by the sequential number (e.g., Reference 4, 

page 1 is expressed as 040001in Reference 4).

2. Hazardous substances are listed by the names used in the January 2004 Superfund Chemical 

Data Matrix (SCDM) (Ref. 2). 

3. Attachment A of this documentation record consists of the following figures:

• A-1 Site Location Map

• A-2A Property Layout Map – US Oil Recovery Property

• A-2B Property Layout Map – MCC Recycling Property

• A-3 Surface Water Pathway Map

• A-4 15-Mile Target Distance Limit

• A-5 Sample Location Map
HRS Documentation Record 4 US Oil Recovery

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REFERENCES CITED

1. 40 Code of Federal Regulations (CFR) Part 300, Hazard Ranking System; Final Rule. 14 

December 1990. Volume 55, No. 241. Pages: 1. [A complete copy can be obtained from the 

Regional Docket upon request or found online at 

http://www.epa.gov/superfund/sites/npl/hrsres/index.htm#HRS Rule].

2. U.S. Environmental Protection Agency (EPA). 2004. Superfund Chemical Data Matrix 

(SCDM) (excerpts). January 2004. Pages: 15. [A complete copy of SCDM is available at 

http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm

3. U.S. Geological Survey (USGS) Topographic Maps. 1995. Pasadena, Texas; 1995, Highlands, 

Texas; 1995, La Porte, Texas (7.5-minute topographic series maps). Pages: 3.

].

4. Weston Solutions, Inc (WESTON®

5. Texas Commission on Environmental Quality (TCEQ). 2011. Preliminary Assessment Report. 

US Oil Recovery. Pasadena, Harris County, Texas. TXR000051540. April 2011. Pages: 920.

). 2010. Project Note to File. Measurement of the Latitude 

and Longitude coordinates at US Oil Recovery. 7 February 2011. Pages: 2.

6. TCEQ. 2010. Preliminary Assessment Report. MCC Recycling. Pasadena, Harris County, 

Texas. TXR000079409. April 2011. Pages: 808.

7. EPA. 2010. Region VI, Pollution Reports 1 through 7. US Oil Recovery. Site # A6X7. 

Pasadena, Texas. 20 June 2010 through 18 November 2010. Pages: 27.

8. TCEQ. 2009. Investigation Report. US Oil Recovery LP. CN602842734. 16 October to 19 

November 2009. Pages: 286.

9. EPA. 2009. Resource Conservation Recovery Act Compliance Evaluation Inspection. US Oil 

Recovery L.P. Pasadena, Texas. TXR000051540. November and December 2009. Pages: 17.

10. WESTON. 2010. Summary of Container Information and Hazardous Categorization Sheets. 

US Oil Recovery Services, Pasadena, Harris County, Texas. 13 through 31 July 2010. Pages:

164.

11. US Oil Recovery LP (USOR). Description of Operations. US Oil Recovery LP and MCC 

Recycling LLP. Date Unknown. Pages: 2.

12. TCEQ. 2009-2010. Investigation Report. MCC Recycling LLP. CN603445016. 8 August 

2009 – 25 March 2010. Pages: 73.

13. WESTON. 2011. Project Note to File. Calculating Approximate Volumes of Surface 

impoundments at 200 N. Richey Street. US Oil Recovery, Pasadena, Harris County, Texas. 11

March 2011. Pages: 4.

14. USOR. 2007. US Oil Recovery LP Equipment Assignment. 5 February 2007 and 20 March 
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2007. Pages: 5.

15. WESTON. 2011. Project Note to File. Calculating Overland Flow Distances. US Oil 

Recovery, Pasadena, Harris County, Texas. 15 March 2011 (updated 25 May 2011). Pages: 2.

16. CLR Search.com. 2011. Pasadena, Texas Weather, Pollution and Natural Disaster Indexes. 

http://www.clrsearch.com/Pasadena_Demographics/TX/Weather_Pollution_and_Natural_Disas

ter_Risk_Indexes. Accessed 15 March 2011. Pages: 1.

17. WESTON. 2011. Project Note to File. Interview with Mr. Steven Andrade Concerning 

Fishing. US Oil Recovery, Pasadena, Harris County, Texas. 8 February 2011. Pages: 2.

18. Harris County Public Health and Environmental Services (HCPHES). 2009. Memorandum. 

Subject: MCC Recycling, LLP (ID15233). 21 December 2009. Pages: 111.

19. US Fish and Wildlife Service. 2011. National Wetlands Inventory. USOR Wetlands. 

Available at http://www.fws.gov/wetlands/Data/Mapper.html. Accessed on 16 March 2011. 

Pages: 13.

20. WESTON. 2011. Project Note to File. Wetland Frontage Distance Measurement. US Oil 

Recovery, Pasadena, Harris County, Texas. 16 March 2011 Pages: 2.

21. EPA. Fact Sheet. Using Qualified Data to Document an Observed Release and Observed 

Contamination. EPA 540-F-94-028. November 1996. Pages: 18.

22. Accutest Laboratories. 2010. Technical Report for US Oil Recovery. Job Number T56085. 

16 July 2010. Pages: 98.

23. WESTON. 2011. Data Quality Assurance Review. SDG T56085. US Oil Recovery. 15 

March 2011. Pages: 63.

24. EPA Region 6 Laboratory. 2011. Draft Final Analytical Report. US Oil Recovery. Project # 

11SF088. 30 March 2011. Pages: 329.

25. WESTON. 2011. Project Note to File. Containment Pond Volume. US Oil Recovery,

Pasadena, Harris County, Texas. 22 March 2011. Pages: 2.

26. WESTON. 2011. Project Note to File. Sample Quantitation Limit Calculation. US Oil 

Recovery, Pasadena, Harris County, Texas. 15 March 2011 (updated 19 May 2011). Pages: 2.

27. WESTON. Field Logbook. WO# 20406.012.001.0570.01. Field Logbook Notes for US Oil 

Recovery Emergency Response Incident 1. 01 July 2010 to 31 July 2010. Pages: 109.

28. WESTON. Field Logbook. WO# 20406.012.001.0570.01. Field Logbook Notes for US Oil 

Recovery Emergency Response Incident 2. 09 November 2010 to 4 March 2011. Pages: 75.

29. WESTON. 2011. Quality Assurance Sampling Plan (excerpts). US Oil Recovery, Pasadena, 
HRS Documentation Record 6 US Oil Recovery

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Harris County, Texas. February 2011. Pages: 123.

30. EPA. Organic Data Assessment. SDG F3SD0, Case 41079 (excerpts). 23 March 2011. Pages: 

238.

31. USGS. Water Data Report. 2010. 08075730 Vince Bayou at Pasadena, Texas. Surface Water 

Records. 2010. Pages: 3.

32. Accutest Laboratories. 2010. Technical Report for US Oil Recovery. Job Number T55622. 9 

July 2010. Pages: 45.

33. WESTON. 2011. Data Quality Assurance Review. SDG T55622. US Oil Recovery. 22 

March 2011. Pages: 22.

34. WESTON. 2011. Project Note to File. Calculating Distance from PPE to Level II Sample

Locations. US Oil Recovery, Pasadena, Harris County, Texas. 28 March 2011. Pages: 2.

35. TCEQ. Texas Risk Reduction Program §350.51(m), Texas-Specific Soil Background 

Concentrations (excerpts). 28 March 2007. Pages: 1.

36. USGS. 2011. Surface Water Annual Statistics for the Nation. USGS 08074000 Buffalo Bayou 

at Houston, Texas. http://waterdata.usgs.gov/usa/nwis/uv?site_no=08074000. Accessed 29 

March 2011. Pages: 1.

37. Environment Texas. Clean Water In the News. Pasadena Citizen. Environmental Group 

Takes Aim at Polluted Ship Channel. 23 October 2009. http://www.environmenttexas.org/inthe-news/clean-water/clean-water/environmental-group-takes-aim-at-polluted-ship-channel.

Accessed 29 March 2011. Pages: 2.

38. EPA. Inorganic Data Assessment. SDG MF3SH8, Case 41079 (excerpts). 18 March 2011. 

Pages: 85.

39. EPA. Organic Data Assessment. SDG F3SG8, Case 41079 (excerpts). 29 March 2011. Pages: 

202.

40. EPA. Inorganic Data Assessment. SDG MF3SD1, Case 41079 (excerpts). 1 April 2011. Pages: 

153.

41. EPA. Inorganic Data Assessment. SDG MF3SG7, Case 41079 (excerpts). 31 March 2011. 

Pages: 106.

42. EPA. Inorganic Data Assessment. SDG MF3SD0, Case 41079 (excerpts). 1 April 2011. Pages: 

104.

43. WESTON. 2011. Project Note to File. Photos from July and November 2011 Responses. US 

Oil Recovery, Pasadena, Harris County, Texas. 1 April 2011. Pages: 27.
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44. WESTON. Trip Report for US Oil Recovery, 400 and 200 N. Richey Street, Pasadena, Harris 

County, Texas (excerpts). 8 April 2011. Pages: 34.

45. Accutest Laboratories. 2011. Technical Report for Weston Solutions, US Oil Recovery. Job 

Number T63728. 23 February 2011. Pages: 56.

46. WESTON. 2011. Project Note to File. Secondary Containment and Sump Volume. US Oil 

Recovery, Pasadena, Harris County, Texas. 12 April 2011. Pages: 2.

47. TCEQ. 2004. Notice of Violation for Compliance Investigations. U.S. Oil Recovery. TCEQ 

ID Nos. 52123, 40202, and A85794. 24 February 2004. Pages: 6.

48. HCPHES. 2010. Violation Notice. U.S. Oil Recovery, L.P. 4 March 2010. Pages: 3.

49. WESTON. 2011. Data Quality Assurance Review. SDG T63728. US Oil Recovery. 11 May 

2011. Pages: 34.

50. Toxics Release Inventory Program. www.epa.gov/TRI/. TRI Explorer search conducted for 

area code 77506. 2009 Public Data. Pages: 8

51. Texas Administrative Code. 2003. Title 31, Part 1, Chapter 19, Subchapter A, Rule§19.2 

Definitions. Amended to be effective 18 September 2003, 28 TexReg 7994. Pages 4.

52. Federal Emergency Management Agency. 2001. Harris County, Texas, and Incorporated 

Areas. Flood Profiles, 100-00-00 (Vince Bayou). 2001. Pages 1.

53. EPA. 2011. Enviromapper for Water database. 

http://map24.epa.gov/EMR/Default.aspx?clearSessionState=true with links to EPA Facility 

Registry System http://oaspub.epa.gov/enviro/. Accessed 7 July 2011. Pages: 6.

54. WESTON. 2011. Project Note to File. Direct Observation Sample Locations. US Oil 

Recovery, Pasadena, Harris County, Texas. 15 July 2011. Pages: 2.
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SITE SUMMARY

The US Oil Recovery (USOR) facility is located at 400 and 200 N. Richey Street in Pasadena, Harris

County, Texas (Ref. 3, p. 1, Ref. 5, p. 10, and Ref. 6, p. 10; Ref. 11, pp. 1, 2). The facility is located in 

a mixed industrial/residential area north of the City of Pasadena, Texas and is depicted on Figure A-1 

of Attachment A (Ref. 3, p. 1). One of the properties (identified as USOR on Figure A-1) consists of a 

centralized waste treatment plant that receives and treats oily waste, sludge, and organic chemicalbearing wastes. The second property (identified as MCC on Figure A-1) consists of two contiguous 

parcels connected by pipes and bisected by Vince Bayou. The MCC property contains an industrial 

wastewater treatment plant (WWTP), MCC Recycling, which is connected to the USOR waste 

treatment property via a 6-inch diameter pipeline. The USOR and MCC properties are approximately 

12.2 acres and 4.70 acres in size, respectively (Ref. 5, p. 11; Ref. 6, pp. 11, 13, 52; Ref. 11, p. 1).

The facility is an abandoned used oil processor and wastewater treatment facility. The USOR waste 

treatment operations at 400 N. Richey Street began in 2002 and the wastewater treatment operations at 

200 N. Richey Street began in 2008 when MCC Recycling became a subsidiary of USOR. As part of 

the operations at the facility, USOR processed non-hazardous landfill leachate, contaminated 

stormwater, wastewater generated from industrial and non-industrial interceptor traps, Class I and 

Class II industrial waste (subject under the wastewater treatment unit exemptions), characteristically 

hazardous waste, used oil and oily sludges, and municipal solid waste (Ref. 5, pp. 62, 286, 305; Ref 7, 

p. 2; Ref. 11, p. 1). Once accepted, the wastes were treated by de-watering via reclamation of 

recyclable materials through neutralization of acidic or caustic characteristics and/or by removal of 

solid materials in the waste through screening, clarification and biological activity. 

Once the waste was accepted by USOR, the waste was separated into several concrete pits. 

Wastewater with five percent solids was sent to the concrete pits to be de-watered and solidified. 

Solids were materialized with limekiln dust, cement kiln dust, sawdust, and/or filter press operation. 

Wastewater with less than five percent solids and decant from the other wastewater pits were piped 

into treatment tanks (Ref. 5, pp. 13, 305). After treatment by USOR, the effluent (an oily water 

mixture) was piped via pipeline to the industrial WWTP (MCC Recycling) located approximately 0.1 

mile to the southeast of the waste treatment operations for further treatment and eventual discharge 

(Ref. 5, pp. 13, 287; Ref. 11, p. 1). 

The USOR property containing the used oil processing and waste treatment operations, also called 

USOR, is located at 400 N. Richey Street and consists of two buildings and a security guard shack. A 

one-story office building (approximately 3,000 square feet) is located at the entrance to the property. 

The second building is a one-story brick and metal rectangular warehouse (approximately 25,000 

square feet in size) that is located near the middle of the property. The warehouse includes a 

laboratory, machine shop, container storage area, and parts warehouse. A tank farm is located at the 

north end of the warehouse. The tank farm contains approximately 24 aboveground storage tanks 

(ASTs). A large concrete walled structure that is called the “aeration basin”, also known as the 

“bioreactors”, is located west of the tank farm. A containment pond is located west of the warehouse 

and south of the aeration basin. The property also contains 225 roll-off boxes located throughout the 

property. The property is currently surrounded by a six-foot chain link fence (Ref. 5, pp.11, 24 Ref. 7, 

p. 10; Ref. 9, p. 2). A Property Layout Map is provided as Figure A-2A.
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The MCC property that receives and treats wastewater from USOR is located at 200 N. Richey Street 

and consists of contiguous properties which include 2.92 acres on the east side of Vince Bayou 

connected by a foot bridge and pipes to 1.78 acres on the west side of Vince Bayou. The 4.70-acre 

property was the former location of the City of Pasadena “old” Vince Bayou WWTP (Ref. 6, pp. 11, 

45-52; Ref. 12, p. 5). The west plant contains the headworks, a trickling filter, a primary clarifier, an 

aeration basin (converted from the final clarifier), and lift stations for transferring wastewater from the 

west plant to the east plant. The east plant has a small gravity thickener near the pump room. The 

pump room is connected to the aerobic digester tank. Between the aerobic digester tank and the 

chlorine contact tank is the belt filter press building. Further toward the back of the property is an 

oxygen activated sludge tank. The remains of a sand filter are next to the oxygen digesters and oxygen 

activated sludge tank. Two final clarifiers (Clarifier #1 and Clarifier #2) are behind the oxygen 

activated sludge tank (Ref. 5, p. 311; Ref. 6, pp. 13, 21, 22, 55; Ref. 9, p. 3). A Property Layout Map

is provided as Figure A-2B.

The closest residences are located approximately 150 feet south of the MCC property. A community 

park is located approximately 650 feet southwest of the facility. The topography of the property is 

generally flat although there is a slight slope across most of the property toward Vince Bayou. The 

slope increases to a moderate slope between the facility and the bayou. The closest probable points of 

entry for overland flow to Vince Bayou are approximately 50 feet west of the waste treatment 

operations at the MCC property and 40 feet east of the USOR wastewater operations property (Ref. 3, 

p. 1; Figure A-3).

For the purpose of this HRS evaluation, the USOR site includes sources on both the USOR and MCC 

Recycling properties and the location of releases from the sources into Vince Bayou. The site includes

the following eight sources: drums (containing flammable and corrosive wastes); bioreactors; truck 

bays used as sumps; surface impoundments; poly totes (containing flammable and corrosive wastes); 

aboveground tanks (ASTs); containment pond; and roll-off boxes. These sources contain hazardous 

substances that have been or potentially could be released into Vince Bayou, which flows in a 

northerly direction from the site. Level II contamination, as a result of releases of hazardous 

substances via overland flow migration and direct deposition, has been documented in both surface 

water and sediment within Vince Bayou. This contamination threatens a nearby human food chain 

fishery and sensitive environments.

• December 2003 and January 2004 - The Texas Commission on Environmental Quality 

(TCEQ) performed a Compliance Evaluation Investigation (CEI) after they received a 

complaint that alleged USOR of improperly transporting hazardous waste and operating 

without a permit or proper registration (Ref. 47, p. 1).

History

The USOR facility has a history of violations and environmental concerns dating back to the early 

beginnings of operations as presented in the following paragraphs: 

• 24 February 2004 - the TCEQ issued a Notice of Violation to USOR. Some of the issues 

noted included: processing grease trap and grit waste without authorization; emission of strong 

foul odor; processing industrial non-hazardous liquid waste in its WWTP, and transporting 
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treated wastewater effluent to the Gulf Coast Waste Disposal Authority for disposal (Ref. 47, p. 

6).

7 October 2005 - The TCEQ Region 12 Waste Program conducted a sampling investigation at 

the site (Ref. 5, p. 16). TCEQ had received a complaint that alleged USOR had discharged 

contaminated stormwater from a pipe located just outside the entrance to the site and dumped 

tank bottom waste into a manhole located on the southeast side of the property. The manhole 

was connected to the sewer line used by USOR to discharge treated wastewater to the City of 

Pasadena (Ref. 5, p. 477). During the site visit, the TCEQ investigator observed a ditch with 

dark colored water between N. Richey Street and the manhole (located off USOR property). 

The TCEQ investigator concluded that the water had appeared to overflow from the manhole 

since the vegetation extending from the manhole was distressed (Ref. 5, p. 477). Soil samples 

were collected around the manhole. The soil sample results showed concentrations of arsenic, 

lead, and mercury exceeding Texas Risk Reduction Program (TRRP) Tier 1 protective 

concentration levels (PCLs) for soil at commercial/industrial sites near the manhole on the 

southeast side of the site and at the stormwater outfall near the front gate (Ref. 5, p. 477) 

• 23 February 2006 - The TCEQ Region 12 Waste Program conducted a site inspection and 

collected soil samples (samples E-1, E-2, and E-3) from three areas behind the 

warehouse/processing building on the USOR property The analytical results for these samples 

showed concentrations of arsenic, barium, lead, mercury, several pesticides including 

toxaphene, SVOCs including benzo(a)pyrene, and VOCs in exceedance of TCEQ’s TRRP Tier 

1 commercial/industrial PCL (Ref. 5, pp. 16, 273, 489-492). 

• 14 December 2008 - Air samples were collected downwind of USOR. The air sampling 

results found benzene, toluene, and xylene concentrations exceeding the TCEQ Effects 

Screening Levels (ESLs) (Ref. 5, pp. 33, 501). 

• 17 December 2007 - The TCEQ Region 12 Waste Program conducted a Sampling 

Investigation at USOR to evaluate compliance with the applicable requirements for industrial 

solid waste (Ref. 5, p. 17). During the investigation, TCEQ investigators found that an 

unauthorized discharge of wastewater onto the ground was occurring from cracks in the west 

wall of the aeration basin. TCEQ took several soil samples (Ref. 5, pp. 17, 338). Two soil 

samples were collected from approximately three feet from the base of the basin. One soil 

sample was collected approximately 58 feet away at the north fence line and two other samples 

were collected on the adjacent downgradient property to the north. Another soil sample was 

collected approximately 88 feet north of the USOR property (Ref. 5, pp. 17, 338). All six soil 

samples displayed concentrations of arsenic, lead, and/or mercury above TRRP Tier 1

residential PCLs (Ref. 5, pp. 17, 338).

• 14 March 2009 - A release of hazardous waste occurred from the west side of the bioreactors

(Ref. 5, p. 17). According to USOR’s spill report, the spilled material migrated north on the 

property about 150 feet and then outside of the property another 200 feet to the north (Ref. 5, p. 

504). Affected soil was excavated and transported off-site to the Fort Bend Landfill (Ref. 5, p. 

505). As part of the incident, the two bioreactors incurred partial structural failure. USOR 

stated that, as of 12 October 2009, 90 percent of the material from the bioreactors had been 

removed (Ref. 9, pp. 3, 4).
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• May through June 2009 - Personnel from TCEQ discovered several spills from the 

wastewater treatment property that migrated into Vince Bayou (Ref. 5, p. 312; Ref. 6, p. 14). 

In each case of the spills discharging into Vince Bayou, there was no evidence of spill 

prevention measures by MCC Recycling. The frequency of the spills, lack of spill prevention or 

containment measures, and the unpermitted discharge indicated negligence by MCC Recycling

(Ref. 9, p. 4). An NOE was issued by TCEQ due to the unpermitted discharges (Ref. 6, p. 14). 

On 8 June 2009, a temporary injunction was granted by the Harris County Court for the site to 

stop receiving wastes until certain conditions were met (Ref. 6, p. 56; Ref. 9, p. 4). 

• August through September 2009 – A TCEQ Water Quality Pretreatment Program 

investigator discovered wastewater escaping to the ground from the trickling filter at the MCC

property (Ref. 6, pp. 16, 56). This was a non-permitted discharge of wastewater. This 

investigation found that the wastewater treatment process had been changed with no prior 

formal notice of the change having been made to TCEQ (Ref. 12, p. 7). At this time, MCC 

was under a temporary injunction issued by Harris County. The injunction required USOR to 

cease the intake of wastewater until verification of the structural soundness of operations and 

proper treatment process could be made by engineers (Ref. 6, p. 56). The injunction further

required the outfall located on the east side of the property to be plugged but it appeared not to 

be (Ref. 6, p. 56). The injunction required the chlorine contact tank to be removed and all open 

tanks or basins to have a freeboard of at least 18 inches (Ref. 9, p. 4). The requirements of the 

two injunctions were not met (Ref. 12, p. 5). During this same time, hydrocarbon odors were 

detected at the headworks, the primary clarifier, the trickling filter, and the aeration basin 

which are located in the west plant. Septic hydrocarbon odors were detected at the aerobic 

digester and gravity thickener located on the east side of the site (Ref. 12, p. 7). Harris County 

Public Health and Environmental Services (HCPHES) issued a violation notice to MCC 

Recycling LLC in a letter dated 27 August 2009 concerning the odor emissions containing

benzene and acetone. The notice also addressed the leaks from the trickling filter and noncompliance issues with the injunction (Ref. 12, p. 7). 

• September through December 2009 - The U.S. Coast Guard issued an Administrative Order 

to USOR to remove the waste from the bioreactors due to the inadequate structural integrity of 

the tank and the proximity of the tank to Vince Bayou (Ref. 5, p. 287). USOR placed 

hazardous waste from the bioreactors in 210 roll-off boxes throughout the USOR site. Each 

roll-off box contained approximately 30 cubic yards of hazardous waste (Ref. 5, p. 287). In 

November and December 2009 EPA inspectors observed these roll-off boxes leaking onto the 

ground. There was no secondary containment to prevent current and future releases of the 

hazardous constituents contained in the roll-off boxes (Ref. 5, p. 288). EPA collected samples 

of the waste contained in several roll-off boxes using the Toxicity Characteristics Leaching 

Procedure (TCLP) analytical method and found that the contents in the roll-off boxes to be 

hazardous waste, containing benzene, 1,2- dichloroethane, and trichloroethylene (Ref. 5, p.

288).

• October and November 2009 - HCPHES investigators discovered discharges from the 

wastewater treatment property in Vince Bayou. A 24-inch ribbed, concrete pipe connected to 

the property had ruptured and was discovered discharging black effluent into Vince Bayou at a 

rate of approximately 200 gallons per minute (Ref. 18, pp. 3-6, 11). Samples were collected 
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from the discharging pipe on 27 October 2009 (Ref. 6, p. 341). Analytical results show that the 

discharged wastewater contained high concentrations of acetone, carbon disulfide, 2-butanone, 

1,2-dichloroethane, benzene, 4-methyl-2-pentanone, toluene, ethylbenzene, and xylenes (Ref. 

6, pp. 17, 422-432).

• 16 November 2009 - The TCEQ Region 12 Waste Program conducted an investigation at 

USOR and found unauthorized hazardous waste being stored in the container storage area (Ref. 

8, p. 8). The following violations were observed in the container storage area: leaking 

containers; containers stored in an unsafe manner; universal waste not stored in separate double 

rows of containers; failure to ensure all containers of hazardous waste were closed or covered;

failure to ensure waste was stored in leak free containers; failure to obtain a RCRA permit to 

store hazardous waste in the aeration basin and in the container storage area; and, failure to 

prevent the discharge or imminent threat of discharge of industrial solid waste or municipal 

hazardous waste into the Vince Bayou (Ref. 5, pp. 288-289; Ref. 8, p. 8).

• 2 December 2009 - HCPHES conducted an inspection at USOR where investigators observed 

a 6-foot pile of soil contaminated with hazardous sludge was observed on the ground behind 

the bioreactors (Ref. 5, pp. 18, 19). The contaminated soil was generated as a result of the 

sludge transfer operation from the bioreactors to the roll-off boxes. No protection barrier was 

observed under the pile of contaminated soil that would prevent runoff from this area draining 

off-site to Vince Bayou (Ref. 5, pp. 18, 19). Other violations observed included failure to notify 

TCEQ of the transfer of hazardous waste sludge from bioreactors (C-63 and C-64) to on-site 

roll-off boxes and failure to mark containers filled with hazardous waste sludge from 

bioreactors with the accumulation start date (Ref. 5, p. 18-19; Ref. 47, pp. 1-3).

EPA inspectors observed the stormwater basin overflowing with an oily sheen discharging into 

Vince Bayou. EPA inspectors observed approximately 200 drums and poly totes in the USOR 

warehouse. Approximately 20 percent of the drums had hazardous waste labels (Ref. 5, pp. 18, 

288). EPA took samples of the drum contents labeled hazardous waste and results confirmed

the drums contained hazardous waste. Samples were also collected from unlabeled drums and 

results indicated the contents contained in the drums were also hazardous waste (Ref. 5, pp. 18, 

288). A sample collected from an unlabeled drum contained methyl ethyl ketone at a 

concentration of 95,400 parts per million (ppm) (Ref. 5, p. 288). USOR did not have 

authorization pursuant to the TCEQ Waste Permit to store hazardous waste in the warehouse or 

any other location on the USOR property (Ref. 5, pp. 18, 288). 

EPA inspectors observed that some drums in the warehouse were leaking and badly 

deteriorating (Ref. 5, p. 289). EPA inspectors observed a shipment of waste dumped directly 

from a truck to the floor of the filter press room. EPA sampled the waste and found the waste 

to be a hazardous waste with a flash point less than 140 degrees Fahrenheit (°F) (Ref. 5, p. 

289). Hazardous waste was observed leaking from a truck and flowing into the containment 

pond (Ref. 5, p. 289). Based on records and recent sampling results, EPA found USOR 

discharged hazardous waste in its effluent to the Pasadena publicly owned treatment works 

(POTW) from 1 July 2009 to 26 December 2009 (Ref. 5, p. 289). Samples results revealed 

effluent contained hazardous wastes exceeding the regulatory limit for benzene and mercury

(Ref. 5, p. 289). As a result of the inspection, EPA inspectors determined that USOR had 
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received numerous shipments of hazardous waste that USOR was not authorized to receive 

and/or treat. Shipment of hazardous waste included lead, vinyl chloride, chromium, silver, and 

at least 50 shipments of metal wastes (Ref. 5, pp. 18, 289).

• January 2010 - Investigators also found roll-off boxes were being used to store hazardous and 

industrial waste without authorization by permit and that these containers were leaking (Ref. 

48, p. 2). Also during this time, an investigator with the TCEQ Water Quality Pretreatment 

Program observed unpermitted discharges into Vince Bayou from the wastewater treatment 

property. A violation was issued due to failure to prevent the unauthorized discharge of 

wastewater into the waters of the State. Wastewater from the old chlorine contact tank was 

discovered discharging from the MCC property to Vince Bayou from two unpermitted outfalls 

on 8 January and 13 January 2010 (Ref. 6, pp. 18, 665).

• July 2010 - Due to a large rainfall event associated with Hurricane Alex, the HCPHES and 

TCEQ reported the potential release of hazardous substances to the National Response Center

(Ref. 5, pp. 19, 63). As a result of these reports, EPA initiated an Emergency Response and 

Removal Action on 2 July 2010 at the USOR site (Ref. 5, pp. 62, 63). EPA found the site to be 

abandoned and that releases of hazardous substances were occurring at the site. Numerous 

roll-off boxes (labeled as containing hazardous waste) were filled with liquid and overflowing 

onto the ground which was then flowing off-site (Ref. 5, pp. 19, 63; Ref. 6, p. 64). Several 

secondary containment areas were overflowing and flowing off-site. The EPA ER team found 

that most of the drums located in the warehouse were not in transportable condition and the

contents of the drums were not labeled correctly (Ref. 5, p. 69). Some drums were found 

leaking and not sealed with the appropriate lids, bungs, or drum rings. Corrosives were stored 

in metal containers and containers holding acids and bases were stored side by side in the 

warehouse (Ref. 5, p 69). Contents in totes located in the warehouse were not consistent with 

the tote labels and contained flammables and corrosives. The majority of the roll-off boxes 

were not properly secured and open to weather conditions (Ref. 5, pp. 19, 63, 69, 74-76, 79, 

88-89). A containment pond located on the western side of the site was sampled and found to 

contain 0.0082 mg/L acetone. The aeration basin located on the northwest corner of the 

property was noted as containing oily waste and its walls were deteriorating (Ref. 5 pp. 19, 74,

327; Ref. 7, p. 2).

On July 7, 2010, after a release at the MCC facility was reported to the National Spill Response 

Center by HCPHES and TCEQ, the EPA included emergency removal actions at MCC (Ref. 6, 

p. 18). During emergency removal activities, three releases were found at the MCC property

and remediated as follows:

o Oily liquid was discharging from the pump house onto the ground and into Vince

Bayou. The release was stopped by plugging the pipes that were leaking (Ref. 6, pp. 18, 

81, 85, 113).

o The east plant lift station, also known as Lift Station #1, was discharging liquid onto the 

ground and into the bar ditch located along West Richey Street and then Vince Bayou. 

The release was stopped by pumping liquid from the lift station into a frac-tank (Ref. 6, 

pp. 18, 87, 89-90).
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o Liquid from the chlorine contact chamber was surfacing from cracks in a concrete road 

near the northwest corner of the chlorine contact chamber. The liquid was running 

across the concrete road, onto the ground, and into Vince Bayou near the northwest 

corner of the east plant. The release was stopped by pumping liquid from the chlorine 

contact chamber into frac-tanks (Ref. 6, p. 19, 74, 81, 83-84, 86, 284, 287).

• 2 August 2010 - EPA completed its Emergency Response and Removal Action and the site, 

which includes both the USOR and MCC Recycling properties, was stabilized (Ref. 5, p. 75). 

A total of 225 roll-off boxes were secured and 797 drums and 212 poly totes were assessed, 

inventoried, and segregated. The drums and poly totes were staged in a safe manner in 

secondary containment areas located inside the warehouse. Placards and painting markings 

were placed at each containment area according to hazardous characterization. Approximately 

392,000 gallons of non-hazardous material was transported off-site for disposal (Ref. 5, pp. 19-

20, 74-75; Ref. 7, p. 19).

• 4 November 2010 - HCPHES reported to the National Response Center that an oily discharge 

was occurring from USOR due to heavy rain. TCEQ requested EPA’s assistance on 8 

November 2010 after visiting the site and confirming the site conditions. EPA activated the 

EPA Emergency and Rapid Response Service (ERRS), who arrived on site on 9 November 

2010 (Ref. 5, pp. 77, 78). After making a complete inspection of the site, EPA found damaged 

containers in the warehouse and the overflow and off-site migration of hazardous substances 

from the USOR site into Vince Bayou (Ref. 5, p. 20, 78, 130-131: Ref. 6, p. 221). EPA ERRS 

personnel recovered liquids from the north and south secondary containment areas (tank 

farms), sumps and bays, and from the parking lot. Approximately 410,000 gallons of nonhazardous oily liquid waste was transported off-site for fuels blending/recycling at the Intergulf 

disposal facility in Pasadena, Texas (Ref. 5, pp. 20, 83; Ref. 7, p. 26). As a result of several

tanks leaking in the north tank farm, oily liquids and sludge from the tanks were drained into 

the containment area. Oily liquids and sludge from the tanks contained high levels of hydrogen 

sulfide and were neutralized for disposal as non-hazardous waste (Ref. 5, pp. 20, 83), A tank 

used to store acid was removed from the secondary containment area since the tank was 

leaking and had damaged the containment area. Concrete was poured into the acid 

containment area to repair the damage (Ref. 5, pp. 20, 83). A total of nine vacuum boxes of 

non-hazardous sludge waste and four vacuum boxes of hazardous sludge were disposed offsite. The non-hazardous sludge was disposed at Waste Management Landfill in Conroe, Texas,

and the hazardous sludge was disposed at U.S. Ecology Texas Inc. in Robstown, Texas (Ref. 5, 

pp. 20, 21, 78). To restrict access, safety fence and orange safety net were placed around the 

warehouse bays. The EPA personnel completed emergency response activities and 

demobilized from the site on 20 December 2010 (Ref. 5, pp. 20-21, 77-78, 83, 381; Ref. 7, p. 

26).

• March 2011 - EPA Superfund Technical Assessment Response and Team (START)-3 

performed supplemental sampling at the USOR site in March 2011. During this time, the 

following samples were collected: 21 surface water and 21 sediment samples (including 2 

duplicates) from within Vince and Little Vince Bayous; 8 surface soil samples (including 1 

duplicate) from overland flow pathways at the site; and 10 waste samples from identified 

sources at the site (Ref. 44, p. 4). The samples were analyzed for Target Compound List (TCL) 
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volatile organic compounds (VOCs), TCL semivolatile organic compounds (SVOCs) by the 

Contract Laboratory Program (CLP) Statement of Work (SOW) for Multi-Media, MultiConcentration Organic Analysis, OLM04.2 and Target Analyte List (TAL) metals with 

mercury by CLP SOW Multi-Media, Multi-Concentration Inorganic Analysis, ISM01.2 (Ref. 44

p. 5). 

Although EPA Emergency Response and Removal Actions took place on the site in 2010 and 2011, the 

activities performed to date were conducted to stabilize the site and all source materials cited in this 

report currently remain on-site (Ref. 7, pp. 1-27). 
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WORKSHEET FOR COMPUTING HRS SITE SCORE

S S2

1. Ground Water Migration Pathway Score (Sgw) NS NS

(from Table 3-1, line 13)

2a. Surface Water Overland/Flood Migration Component 100 10,000

(from Table 4-1, line 30)

2b. Ground Water to Surface Water Migration Component NS NS

(from Table 4-25, line 28)

2c. Surface Water Migration Pathway Score (Ssw) NS NS

(Enter the larger of lines 2a and 2b as the pathway score)

3. Soil Exposure Pathway Score (Ss) NS NS

(from Table 5-1, line 22)

4. Air Migration Pathway Score (Sa) NS NS

(from Table 6-1, line 12)

5. Total of Sgw

2 + Ssw2 + Ss2 + Sa2 ---- 10,000

6. HRS Site Score: Divide the value on line 5 by 4 and take 50.00

the square root.

Notes:

S Score

S2 Score squared

NS Not scored

Tables 3-1, 4-1, 4-25, 5-1, and 6-1 refer to score sheets presented in the HRS Rule (Ref. 1). Table 4-1 is reproduced in the 

following pages of this HRS documentation record for the convenience of the reader.
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DRINKING WATER THREAT - Not Scored (NS)

Factor Categories and Factors Maximum Value Value Assigned

 

Likelihood of Release

1. Observed Release 550 550 

2. Potential to Release by Overland Flow:

2a. Containment 10 NS 

2b. Runoff 25 NS 

2c. Distance to Surface Water 25 NS 

2d. Potential to Release by Overland Flow

 (lines 2a[2b + 2c]) 500 NS 

3. Potential to Release by Flood:

3a. Containment (Flood) 10 NS 

3b. Flood Frequency 50 NS 

3c. Potential to Release Flood

 (lines 3a x 3b) 500 NS 

4. Potential to Release

(lines 2d + 3c, subject to a maximum of 500) 500 NS 

5. Likelihood of Release (higher of lines 1 and 4) 550 550 

Waste Characteristics

6. Toxicity/Persistence a NS 

7. Hazardous Waste Quantity a NS 

8. Waste Characteristics

(Toxicity/Persistence x Hazardous Waste 

 Quantity, then assign a

value from Table 2-7) 100 NS 

Targets

9. Nearest Intake 50 NS 

10. Population

10a. Level I Concentrations b NS 

10b. Level II Concentrations b NS 

10c. Potential Contamination b NS 

10d. Population

(lines 10a + 10b + 10c) b NS 

11. Resources 5 NS 

12. Targets (lines 9 + 10d +11) b NS 

Drinking Water Threat Score

13. Drinking Water Threat Score

[(lines 5 x 8 x 12)/82,500

subject to a maximum of 100] 100 NS 
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HUMAN FOOD CHAIN THREAT

Factor Categories and Factors Maximum Value Value Assigned

Likelihood of Release

14. Likelihood of Release

(Same value of line 5) 550 550 

Waste Characteristics

15. Toxicity/Persistence/ Bioaccumulation a 5x108

 

16. Hazardous Waste Quantity a 100 

17. Waste Characteristics

(Toxicity/Persistence/Bioaccumulation x Hazardous Waste 

Quantity, then assign a

value from Table 2-7) 1,000 320 

Targets

18. Food Chain Individual 50 45 

19. Population

19a. Level I Concentrations b 0 

19b. Level II Concentrations b 0.03

19c. Potential Human Food Chain Contamination b 0.000303

19d. Population

(lines 19a + 19b + 19c) b 0.030303 

20. Targets (lines 18 + 19d) b 45.030303 

Human Food Chain Threat Score

21. Human Food Chain Threat Score

[(lines 14 x 17 x 20)/82,500

subject to a maximum of 100] 100 96.0646464
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ENVIRONMENTAL THREAT

Factor Categories and Factors Maximum Value Value Assigned

Likelihood of Release

22. Likelihood of Release

(Same value of line 5) 550 550 

Waste Characteristics

23. Ecosystem Toxicity/Persistence Bioaccumulation a 5x108

 

24. Hazardous Waste Quantity a 100 

25. Waste Characteristics

(Ecosystem Tox./Persistence x Bioaccumulation x

Hazardous Waste Quantity, then assign a

value from Table 2-7) 1,000 320

Targets

26. Sensitive Environments

26a. Level I Concentrations b 0 

26b. Level II Concentrations b 25 

26c. Potential Contamination

26c. Potential Contamination b 0 

26d. Sensitive Environments

(lines 26a + 26b + 26c) b 25 

27. Targets (value from line 26d) b 25 

Environmental Threat Score

28. Environmental Threat Score

[(lines 22 x 25 x 27)/82,500

subject to a maximum of 60] 60 53.33 

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE FOR A WATERSHED

29. Watershed Score 

[(Lines 13 + 21+ 28), 

subject to a maximum of 100] 100 100

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORE

30. Component Score 

(Highest score from Line 29

for all watersheds evaluated, 

subject to a maximum of 100) 100 100
Source Characterization - Source 1

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SOURCE DESCRIPTION

2.2 Source Characterization

Source Description: Source 1 – Drums (Flammable and Corrosive)

A total of 797 55-gallon drums containing acids, bases, flammables, oxidizers, hydrogen sulfide, and 

Resource Conservation and Recovery Act (RCRA) non-hazardous solids and liquids are present onsite at the USOR property (Ref. 7, p. 19). Of these, a total of 357 drums contain flammable liquids, 

solids, sludge, or gel and 60 drums contain corrosive liquids, solids, sludge or gel (Ref. 10, pp. 1-63). 

Several of the drums were found open, not appropriately labeled or dated, were in poor condition and 

appeared to have leaked (Ref. 7, p. 18; Ref. 10, pp. 1-63; Ref. 43, pp. 5, 9, 11, 12). The area of the 

warehouse (also known as the Container Storage Area) where the drums were found was not 

authorized to store hazardous waste. The following was also noted during a 15 November 2009 TCEQ 

inspection: leaking containers; containers stored in an unsafe manner; universal waste not stored in 

separate double rows of containers from non-hazardous waste; inadequate aisle space; open containers 

storing waste; and storage of liquid waste (Ref. 8, pp. 8, 110-114, 117, 118, 123-138, 140-143). As 

part of the EPA ER activities conducted in July 2010, EPA contractors performed hazardous 

categorization of the drums and staged the drums within the warehouse according to their waste 

streams. Since adequate containment of the drums was not evident prior to July 2010, secondary 

containment areas were built to ensure all containers were stable and not staged in an unsafe manner 

(Ref. 7, p. 19). 

Source Type

The waste contents are in drums (Ref. 7, pp. 18-19) and as such, the source type for Source 1 is 

“Drum” (Ref. 1, Table 2-5).

Source Location

All of the drums are located within the Container Storage Area of the centralized USOR property at 

400 N. Richey (Ref. 7, p. 18; Ref. 27, p. 7; Ref. 43, pp. 5, 9, 11, 12). The location of the Container 

Storage Area is depicted on Attachment A, Figure A-2A.

Contents of the drums were previously exposed to precipitation and potentially surface water (through 

runoff and flooding) and were in direct contact with floodwater (Ref. 6, pp. 68, 97, 100, 101, 102, 120, 

187, 208, 211). Before the EPA response activities in July 2010 to secure and properly stage the 

drums, several of the drums were found opened and in varying states of disrepair (Ref 7, p. 18; Ref. 

10, pp. 1-63; Ref. 43, pp. 5, 9, 11, 12). During inspections of the USOR property conducted in 

November and December 2009 by EPA, TCEQ, and/or HCPHES, drums located within the Container 

Storage Area were observed to be leaking, badly deteriorated, and lacking secondary containment 

(Ref. 5, pp. 18, 75, 288-289; Ref. 8, pp. 8, 110-119, 123-138, 140-142). Since the EPA response 

Source Containment

Release To Surface Water
Source Characterization - Source 1

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activities in 2010 have placed the drums within secondary containment, a containment value of 9 was 

selected for Source 1 based on the current containment conditions, but the site is currently abandoned, 

and there is no maintenance of the containment area (Ref. 1, Table 4-2).

Containment Value: 9

2.4.1 Hazardous Substances

As part of supplemental sampling of the USOR site from 01 through 04 March 2011, the EPA Region 

6 START-3 contractor collected waste sample from two of the drums (D0745 and D0761) (Ref. 28, p. 

73; Ref. 44, p. 4). These drums were located within the warehouse of the USOR property at 400 N. 

Richey Street (Ref. 5, pp. 13, 62, 69, 75). Drums D0745 and D0761 were sampled based on their 

hazardous categorization results and were identified by EPA START-3 as a Corrosive Acid with a pH 

less than 3 and as a Flammable Liquid (Ref. 10, pp. 60, 61). The samples were analyzed for VOCs 

and SVOCs by CLP OLM04.2 and for TAL metals and mercury by CLP ISM01.2 by the EPA Region 

6 Environmental Services Branch Laboratory (Ref. 24, pp. 171-182,326; Ref. 28, p. 73; Ref. 29, p. 19; 

Ref. 44, pp. 4, 5). 

Analytical evidence of the contamination in waste source samples associated with the two drums 

located on the USOR site is summarized below. 

Hazardous

Substance

Evidence

References Sample ID Concentration

(mg/L)

Reporting Limit

EPA Supplemental Sampling Activities – March 2011 

1

(mg/L)

Acetone D0745-00-81 0.0892 0.010 Ref. 24, pp. 171, 326; Ref. 28, p. 73

2-Butanone D0745-00-81 0.173 L 0.050 Ref. 24, pp. 171, 326,;Ref. 28, p. 73

Benzoic Acid D0745-00-81 0.948 J 0.10 Ref. 24, pp. 173, 326; Ref. 28, p. 73

Cobalt D0745-00-81 7.83 2 Ref. 24, pp. 176, 326; Ref. 28, p. 73

Manganese D0745-00-81 852 0.5 Ref. 24, pp. 176, 326; Ref. 28, p. 73

Nickel D0745-00-81 5,400 2 Ref. 24, pp. 176, 326; Ref. 28, p. 73

Zinc D0745-00-81 14,700 2 Ref. 24, pp. 176, 326; Ref. 28, p. 73

Cyclohexane D0761-00-81 202 20 Ref. 24, pp. 177, 326; Ref. 28, p. 73

Benzene D0761-00-81 37.9 20 Ref. 24, pp. 177, 326; Ref. 28, p. 73

Methylcyclohexane D0761-00-81 844 20 Ref. 24, pp. 177, 326; Ref. 28, p. 73

Toluene D0761-00-81 618 20 Ref. 24, pp. 178, 326; Ref. 28, p. 73

Ethylhexylbenzene D0761-00-81 458 20 Ref. 24, pp. 178, 326; Ref. 28, p. 73

meta/para-Xylene D0761-00-81 1,480 40 Ref. 24, pp. 178, 326; Ref. 28, p. 73

ortho-Xylene D0761-00-81 703 20 Ref. 24, pp. 178, 326; Ref. 28, p. 73

Isopropylbenzene D0761-00-81 163 20 Ref. 24, pp. 178, 326; Ref. 28, p. 73

1,1’-Biphenyl D0761-00-81 208 97.1 Ref. 24, pp. 179, 326; Ref. 28, p. 73

2-Methylnaphthalene D0761-00-81 715 38.8 Ref. 24, pp. 180, 326; Ref. 28, p. 73

Naphthalene D0761-00-81 372 38.8 Ref. 24, pp. 180, 326; Ref. 28, p. 73
Source Characterization - Source 1

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Hazardous

Substance

Evidence

References Sample ID Concentration

(mg/L)

Reporting Limit

Phenanthrene

1

(mg/L)

D0761-00-81 101 38.8 Ref. 24, pp. 181, 326; Ref. 28, p. 73

Pyrene D0761-00-81 67.6 38.8 Ref. 24, pp. 181, 326; Ref. 28, p. 73

Notes:

(mg/L) milligrams per liter = 1,000 micrograms per liter (ug/L)

J Identification of analyte is acceptable; the reported value is an estimate Ref. 24, p. 328.

L Identification of analyte is acceptable; reported value may be biased low, Ref. 24, p. 328

H Identification of analyte is acceptable; reported value may be biased high, Ref. 24, p.328. 1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory is adjusted for sample aliquot, sample volume, and 

dilutions for the analysis and meets the definition of Sample Quantitation Limit (SQL) as defined by the HRS (Ref. 1, Section 1.1;

Ref. 24, p. 4; Ref. 26).

2.4.2 Hazardous Waste Quantity

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1 Tier A: Hazardous Constituent Quantity- Not Evaluated (NE)

The information available is not sufficient to adequately determine a hazardous constituent quantity

with reasonable confidence for Source 1 (Ref. 1, Section 2.4.2.1.1). Scoring proceeds to the evaluation 

of Tier B, hazardous wastestream quantity (Ref. 1, Section 2.4.2.1.2).

2.4.2.1.2 

Waste Stream

Tier B: Hazardous Wastestream Quantity

As part of the EPA emergency response activities, a total of 357 drums containing flammable liquids, 

solids, sludge, or gel and 60 drums containing corrosive liquids, solids, sludge or gel were found 

within the Container Storage Area at 400 N. Richey (Ref. 7, p. 19; Ref. 8, pp. 8, 110-114, 117-119, 

123-142; Ref. 10, pp. 1-63). As presented below, the volume of each drum was estimated during 

container inventory and HAZCAT activities conducted during the July 2010 EPA Emergency 

Response (Ref. 7, p. 19, Ref. 10, pp. 1-86). During EPA response activities in July 2010, drummed 

waste was separated into waste streams that contained similar chemical traits using hazardous 

characterization (HAZCAT) techniques (Ref. 7, p. 19). The remaining 440 drums stored at the facility

were not included in the hazardous wastestream quantity calculation since HAZCAT results did not 

identify their contents as RCRA hazardous waste exhibiting the characteristics indentified under 

Section 3001 of RCRA as amended (Ref. 1, Section 2.4.2.1.2; Ref. 10, pp. 1-86). The following table 

presents a summary of the hazardous waste streams identified and their quantities (Ref. 10, pp. 1-86).

Matrix Volume in Gallons

(approximate) References

Combustible, Corrosive Acid Liquid 94 Ref. 10, pp. 29, 48

Corrosive Acid Liquid 1300 Ref. 10, pp. 5,7,10,11, 17,18,28,29,32-

34,36,42,47,48,49,59,60,61

Corrosive Base Liquid 400 Ref. 10, pp. 9, 15, 17
Source Characterization - Source 1

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Waste Stream Matrix Volume in Gallons

(approximate) References

Flammable Liquid 12000 Ref. 10, pp. 1-3, 5-11, 13-16, 18-62

Flammable, Corrosive Acid Liquid 170 Ref. 10, pp. 33, 34

Flammable, Corrosive Base Liquid 41 Ref. 10, pp. 23, 30, 31, 36, 62

Subtotal Volume of Liquids 14,005

Flammable Sludge 690 Ref. 10, pp. 6, 9, 20, 22, 24, 27, 30, 

35,40, 41, 42, 52,53, 56,

Subtotal Volume of Sludge 690

Corrosive Acid Gel 55 Ref. 10, p. 2

Corrosive Base Gel 44 Ref. 10, p. 31

Flammable Gel 670 Ref. 10, pp. 2, 10, 12, 21,22, 23, 51,52,

Subtotal Volume of Gel 769

Corrosive Acid Liquid/Solid 50 Ref. 10, p. 7

Flammable Liquid/Solid 50 Ref. 10, pp. 7, 12, 45,

Subtotal Volume of Liquid/Solids 100

Corrosive Acid Solid 240 Ref. 10, pp. 7,12, 47, 49,59

Flammable Solid 1100 Ref. 10, pp. 3, 5, 6, 11- 13, 20, 23, 24, 

26- 28, 30, 31, 34, 41, 42, 44-46, 48, 50, 

54 ,58, 61

Flammable, Corrosive Base Solid 44 Ref. 10, p. 31

Subtotal Volume of Solids 1,384

Total Volume of Hazardous 

Waste Stream Drums 16,948

The total volume of the drums (liquids and solids) was calculated based on the container size (55 

gallons) and the content level of each drum determined during inventory (Ref. 10, pp. 1-86). The total 

volume of the drums containing hazardous substances equals 16,948 gallons. The Tier B equation for 

assigning a value for Hazardous Waste stream Quantity (W) is W (in pounds)/5,000 (Ref. 1, Table 2-

5).

Volume of source (gallons): 16,948

1 gallon = 10 pounds (Ref. 1, Table 2-5)

16,948 gallons = 169,480 pounds (lbs)

Hazardous Waste stream Quantity = 169,480 lbs/5,000

Hazardous Waste stream Quantity = 33.896
Source Characterization - Source 1

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2.4.2.1.3 Tier C: Volume - Not Evaluated (NE)

Tier B, the hazardous waste stream quantity of the source has been estimated with reasonable 

confidence, therefore the value assigned for Tier C is not evaluated (Ref. 1, Section 2.4.2.1.4). 

Volume Assigned Value = Not Evaluated

2.4.2.1.4 Tier D: Area - Not Evaluated (NE)

Tier B, the hazardous waste stream quantity of the source has been estimated with reasonable 

confidence, therefore the value assigned for Tier D is not evaluated (Ref. 1, Section 2.4.2.1.4). 

Area Assigned Value = Not Evaluated

2.4.2.1.5

Tier Evaluated

Source Hazardous Waste Quantity Value

Per the HRS, the highest of the values assigned to the source for hazardous constituent quantity (Tier 

A), hazardous wastestream quantity (Tier B), Volume (Tier C), and Area (Tier D) should be assigned 

as the source hazardous waste quantity value (Ref. 1, Section 2.4.2.1.5).

Source 1 Values

A Not Evaluated

B 33.896

C Not Evaluated

D Not Evaluated

Source Hazardous Waste Quantity Value: 33.896
Source Characterization - Source 2

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SOURCE DESCRIPTION

2.2 Source Characterization

Source Description: Source 2 – Bioreactors

The bioreactors (also known as aeration basin) are two contiguous rectangular, steel-reinforced,

concrete open-topped tanks with capacities of 330,000 gallons each. They are permitted through the 

State of Texas as non-hazardous wastewater treatment tanks located on the northwest side of the 400 

N. Richey Street property. These bioreactors are collectively known as the aeration basin because the 

original purpose of the units was to treat organics in wastewater with bacteria kept alive through an 

aerating process with oxygen (Ref. 8, p. 2). In a letter dated 14 April 2008, USOR advised the TCEQ 

that the bioreactors were no longer being used as aeration basins, but were being used for waste 

equalization. On 14 March 2009, the bioreactors suffered a structural failure and released 

approximately 200,000 gallons of wastewater to the surrounding soil when a section of concrete 

separated from the top of the west wall (Ref. 8, pp. 2, 11, 87, 150). Additionally, the west and east 

walls bowed outward apparently due to pressure exerted against the walls by wastewater. Additionally 

significant cracks, primarily in the long (east and west) walls near the corners were discovered (Ref. 8, 

p. 277; Ref. 43, pp. 3, 4). USOR excavated the contaminated soil, stabilized the basin, and ceased 

using the bioreactors as wastewater treatment units. The bioreactors, therefore, became waste storage 

units on 14 March 2009 (Ref. 8, p. 2). Samples collected by USOR from the bioreactors on 27 

September 2009 were found to be hazardous for benzene per a letter dated 30 September 2009 from 

USOR to the United States Coast Guard (Ref. 8, pp. 16, 251-259). 

Source Type

The waste contents are in concrete open-topped tanks and, as such, the source type for Source 2 is 

“Surface Impoundment” (Ref. 1, Table 2-5).

Source Location

The bioreactors are located on the north end of the 400 N. Richey Street property and are shown on

Attachment A, Figure A-2A.

• In December 2007, TCEQ investigators found that an unauthorized discharge of wastewater 

onto the ground was occurring from cracks in the west wall of the aeration basin (also 

known as bioreactors) (Ref. 5, pp. 17, 338).

Source Containment

Release To Surface Water

The contents of the bioreactors are exposed to precipitation and surface water (through flooding) (Ref. 

6, pp. 92, 94, 100, 106, 170, 178, 199, 232-234). Evidence of hazardous substance migration from 

Source 2 is documented below.

• A release of hazardous waste occurred from the west side of the bioreactors in March 2009. 

Several hundred gallons of waste spilled to the ground and ran north about 350 feet towards 
Source Characterization - Source 2

HRS Documentation Record 26 US Oil Recovery

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Vince Bayou (Ref. 5, pp. 17, 504; Ref. 9, pp. 3-4).

• On 5 November 2010, TCEQ observed leaking from several small holes in the north wall of 

the bioreactor. The leaking liquid was going onto the ground (Ref. 5, p. 131).

A containment value of 10 was selected for Source 2 based on the evidence cited above of hazardous 

substance migration from the bioreactors and the lack of spill prevention containment measures at the 

site (Ref. 1, Table 4-2).

Containment Value: 10

2.4.1 Hazardous Substances

On 17 December 2007, the TCEQ Region 12 Waste Program collected soil samples adjacent to and 

downgradient of the bioreactors following discovery of an unauthorized discharge from cracks in the 

west wall of the bioreactors. All six of the soil samples collected contained concentrations of arsenic, 

lead, and/or mercury exceeding TCEQ TRRP Tier 1 residential PCLs (Ref. 5, pp. 17, 338).

As part of the supplemental sampling conducted at the USOR site on 01 through 04 March 2011, EPA 

START-3 collected a waste sample from the bioreactor (WW-02) (Ref. 28, p. 73; Ref. 44, p. 4). The 

sample was analyzed for VOCs and SVOCs by CLP OLM04.2 and for TAL metals and mercury by 

CLP ISM05.3 by the EPA Region 6 Environmental Services Branch Laboratory (Ref. 24, pp. 165-170, 

325). 

Analytical evidence of the contamination in waste source sample associated with the bioreactors 

(classified as source type “Tanks and Containers Other Than Drums”) located on the USOR site is 

summarized in the following table. 

Hazardous

Substance

Evidence

Sample References

ID Concentration RL Units 1

EPA Supplemental Sampling Activities – March 2011 

Acetone WW-02-00-11-20110303 0.774 0.10 mg/L Ref. 24, pp. 165, 325 ; Ref. 28, p. 73

Methylene chloride WW-02-00-11-20110303 0.0260 0.002 mg/L Ref. 24, pp. 165, 325 ; Ref. 28, p. 73

Methyl acetate WW-02-00-11-20110303 0.0159 0.002 mg/L Ref. 24, pp. 165, 325 ; Ref. 28, p. 73

Methy tert-butyl ether WW-02-00-11-20110303 0.0074 0.002 mg/L Ref. 24, pp. 165, 325 ; Ref. 28, p. 73

2-Butanone WW-02-00-11-20110303 0.519 0.05 mg/L Ref. 24, pp. 165, 325 ; Ref. 28, p. 73

1,2-Dichloroethane WW-02-00-11-20110303 0.0038 0.002 mg/L Ref. 24, pp. 165, 325 ; Ref. 28, p. 73

Benzene WW-02-00-11-20110303 0.0316 0.002 mg/L Ref. 24, pp. 165, 325 ; Ref. 28, p. 73

Trichloroethene WW-02-00-11-20110303 0.0033 0.002 mg/L Ref. 24, pp. 165, 325 ; Ref. 28, p. 73

4-Methyl-2-pentanone WW-02-00-11-20110303 0.0112 0.005 mg/L Ref. 24, pp. 166, 325 ; Ref. 28, p. 73

Toluene WW-02-00-11-20110303 0.0104 0.002 mg/L Ref. 24, pp. 166, 325 ; Ref. 28, p. 73

2-Hexanone WW-02-00-11-20110303 0.0094 0.005 mg/L Ref. 24, pp. 166, 325 ; Ref. 28, p. 73

Ethylbenzene WW-02-00-11-20110303 0.0035 0.002 mg/L Ref. 24, pp. 166, 325 ; Ref. 28, p. 73

meta-/para-Xylene WW-02-00-11-20110303 0.0138 0.004 mg/L Ref. 24, pp. 166, 325 ; Ref. 28, p. 73

ortho-Xylene WW-02-00-11-20110303 0.0056 0.002 mg/L Ref. 24, pp. 166, 325 ; Ref. 28, p. 73
Source Characterization - Source 2

HRS Documentation Record 27 US Oil Recovery

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Hazardous

Substance

Evidence

Sample References

ID Concentration RL Units 1

Acetophenone WW-02-00-11-20110303 0.120 0.10 mg/L Ref. 24, pp. 167, 325 ; Ref. 28, p. 73

Benzoic acid WW-02-00-11-20110303 4.71 J 2.0 mg/L Ref. 24, pp. 167, 325 ; Ref. 28, p. 73

Bis(2-ethylhexyl)phthalate WW-02-00-11-20110303 0.506 0.10 mg/L Ref. 24, pp. 167, 325 ; Ref. 28, p. 73

Di-n-butyl phthalate WW-02-00-11-20110303 0.497 0.10 mg/L Ref. 24, pp. 168, 325 ; Ref. 28, p. 73

2-Methylnaphthalene WW-02-00-11-20110303 0.0618 0.04 mg/L Ref. 24, pp. 168, 325 ; Ref. 28, p. 73

3&/or4-Methylphenol WW-02-00-11-20110303 0.338 0.10 mg/L Ref. 24, pp. 168, 325 ; Ref. 28, p. 73

Naphthalene WW-02-00-11-20110303 0.226 0.04 mg/L Ref. 24, pp. 168, 325 ; Ref. 28, p. 73

Phanathrene WW-02-00-11-20110303 0.187 0.04 mg/L Ref. 24, pp. 169, 325 ; Ref. 28, p. 73

Phenol WW-02-00-11-20110303 5.61 1.0 mg/L Ref. 24, pp. 169, 325 ; Ref. 28, p. 73

Barium WW-02-00-11-20110303 0.110 0.10 mg/L Ref. 24, pp. 170, 325 ; Ref. 28, p. 73

Manganese WW-02-00-11-20110303 0.49 0.050 mg/L Ref. 24, pp. 170, 325 ; Ref. 28, p. 73

Nickel WW-02-00-11-20110303 0.317 0.20 mg/L Ref. 24, pp. 170, 325 ; Ref. 28, p. 73

Zinc WW-02-00-11-20110303 1.9 0.20 mg/L Ref. 24, pp. 170, 325 ; Ref. 28, p. 73

Notes:

(mg/L) milligrams per liter = 1,000 micrograms per liter (ug/L)

J Identification of the analyte is acceptable; the reported value is an estimate (Ref. 24, p. 328). 1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory is detection limits which have been adjusted for sample 

aliquot, sample volume, and dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Section 1.1; Ref. 24, p. 4; Ref. 

26).

2.4.2 Hazardous Waste Quantity

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1 Tier A: Hazardous Constituent Quantity - Not Evaluated (NE)

The information available is not sufficient to adequately determine a hazardous constituent quantity 

with reasonable confidence for Source 2 (Ref. 1, Section 2.4.2.1.1). Scoring proceeds to the evaluation 

of Tier B, hazardous wastestream quantity (Ref. 1, Section 2.4.2.1.2).

2.4.2.1.2 Tier B: Hazardous Wastestream Quantity - Not Evaluated (NE)

The information available is not sufficient to adequately determine a hazardous wastestream quantity 

with reasonable confidence for Source 2 (Ref. 1, Section 2.4.2.1.2). Scoring proceeds to the evaluation 

of Tier C, volume (Ref. 1, Section 2.4.2.1.3).

2.4.2.1.3

The quantity volume of the bioreactors was determined by measurements obtained by using GIS

software, and the assumed maximum permissible fluid depth. GIS software contains recent aerial 

photography of the site, which allows the user to trace an area and determine length and width 

measurements of the bioreactor. Using this methodology, the bioreactors were determined to measure 

120 feet x 60 feet with a fluid depth of 11 feet (Attachment A, Figure A-2A; Ref. 8, p., 279; Ref. 25). 

Tier C: Volume
Source Characterization - Source 2

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The Tier C equation for assigning a value for volumes of a source type “Surface Impoundment” is

V/2.5 (Ref. 1, Table 2-5).

120 x 60 x 11 = 79,200 cubic feet

79,200 cubic feet / 27 cubic feet per 1 cubic yard = 2,933.333 cubic yards

Volume of source (cubic yards): 2,933.333

Volume Assigned Value = 2,933.333/2.5

Volume Assigned Value = 1,173.333

2.4.2.1.4 Tier D: Area - Not Evaluated (NE)

Tier C, volume, has already been determined; therefore, the value assigned for Tier D is not evaluated 

(Ref. 1, Section 2.4.2.1.4). 

Area Assigned Value = 0

2.4.2.1.5

Tier Evaluated

Source Hazardous Waste Quantity Value

Per the HRS, the highest of the values assigned to the source for hazardous constituent quantity (Tier 

A), hazardous wastestream quantity (Tier B), volume (Tier C), and area (Tier D) should be assigned as 

the source hazardous waste quantity value (Ref. 1, Section 2.4.2.1.5).

Source 2 Values

A Not Evaluated

B Not Evaluated

C 1,173.333

D 0

Source Hazardous Waste Quantity Value: 1,173.333
Source Characterization - Source 3

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SOURCE DESCRIPTION

2.2 Source Characterization

Source Description: Source 3 - Truck Bays used as Sumps

The truck bay sumps (also known as Bays 34 through 36) on the USOR property contain significant 

volumes of oily waste and sludge and have several visibly leaking weep holes (Ref. 5, pp. 14, 380, 

422: Ref 6, pp. 102, 214). On 1 June 2006, a TCEQ investigator also observed oily waste migrating 

outside the secondary containment to the concrete truck unloading/staging area (the truck bay sumps)

(Ref. 5, pp. 16, 495, 496).

Source Type

The waste contents are in concrete open-top structures, as such, the source type for Source 3 is 

“Surface Impoundment” (Ref. 1, Table 2-5).

Source Location

The truck bay sumps are located on the north side of the 400 N. Richey Street property and are shown 

on Attachment A, Figure A-2A.

On 15 and 16 November 2010, as part of EPA’s emergency response activities, EPA START-3 

collected one composite sample that was collected from three truck bays which were used as sumps 

(also known as sumps 34, 35 and 36) (WP03) (Ref. 28, pp. 18, 22). The sample was hand delivered to 

Source Containment

Release To Surface Water

The contents of the truck bay sumps are exposed to precipitation and surface water (through flooding) 

(Ref. 6, pp. 79, 80, 100, 102, 106, 141, 151, 152, 199, 214, 235). During one large rainfall event in 

July 2010, TCEQ found the truck bays were overflowing oily liquids into the parking lot area, which 

was then discharging down the property’s front driveway and into Vince Bayou (Ref. 5, pp. 19, 88, 

89). In November 2010, the available freeboard in the truck bay sumps (also known as Sumps 34 

through 36) had become compromised due to heavy rains and the contents were overflowing to the 

parking lot (Ref. 6, pp. 105, 226-231; Ref. 7, p. 22). On 1 June 2006, a TCEQ investigator also 

observed oily waste migrating outside the secondary containment to the concrete truck 

unloading/staging area (Ref. 5, pp. 16, 495, 496).

 

A containment value of 10 was selected for Source 3 based on the evidence of hazardous substance 

migration from the truck bay sumps and the lack of spill prevention containment measures at the site 

(Ref. 1, Table 4-2).

Containment Value: 10

2.4.1 Hazardous Substances
Source Characterization - Source 3

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Accutest Laboratories located in Houston, Texas. The sample was analyzed for Toxicity 

Characteristic Leaching Procedure (TCLP) VOCs by SW846 1311/8260B, TCLP SVOCs by SW846 

1311/8270C, and Resource Conservation and Recovery Act (RCRA) list total and TCLP metals with 

mercury by SW846 1311/6010B/7470A (Ref. 45, p. 24).

Analytical evidence of the contamination in waste source samples associated with the Truck Bay 

Sumps (classified as source type “Surface Impoundments”) located on the USOR site is summarized in 

the following table. 

Hazardous

Substance

Evidence

Sample References

ID Concentration MQL Units 1

Benzene WP03-71-101116 0.273 0.25 3 mg/L Ref. 45, pp. 18, 24; Ref.49, pp. 1,8

Methyl ethyl ketone WP03-71-101116 0.320 JQ 0.50 3 mg/L Ref. 45, pp. 18, 24; Ref.49, pp. 1,8

2-Methylphenol WP03-71-101116 0.0353 JQ 0.050 3 mg/L Ref. 45, pp. 19, 24; Ref.49, pp. 9, 16

3&4-Methylphenol WP03-71-101116 0.0797 0.050 3 mg/L Ref. 45, pp. 19, 24; Ref.49, pp. 9, 16

Barium WP03-71-101116 0.21 JQK 5.0 3 mg/L Ref. 45, pp. 20, 24; Ref.49, pp. 17, 27

Chromium WP03-71-101116 0.021 JQK 0.050 3 mg/L Ref. 45, pp. 20, 24; Ref.49, pp. 17, 27

Arsenic WP03-71-101116 5.5 0.68 mg/kg Ref. 45, pp. 22, 24; Ref.49, pp. 17, 24

Barium WP03-71-101116 518 14 mg/kg Ref. 45, pp. 22, 24; Ref.49, pp. 17, 24

Cadmium WP03-71-101116 0.50 0.34 mg/kg Ref. 45, pp. 22, 24; Ref.49, pp. 17, 24

Chromium WP03-71-101116 40.9 0.68 mg/kg Ref. 45, pp. 22, 24; Ref.49, pp. 17, 24

Lead WP03-71-101116 45.3 0.68 mg/kg Ref. 45, pp. 22, 24; Ref.49, pp. 17, 24

Mercury WP03-71-101116 9.5 0.96 mg/kg Ref. 45, pp. 22, 24; Ref.49, pp. 17, 24

Selenium WP03-71-101116 0.96 0.68 mg/kg Ref. 45, pp. 22, 24; Ref.49, pp. 17, 24

Silver WP03-71-101116 0.60JQ 0.68 mg/kg Ref. 45, pp. 22, 24; Ref.49, pp. 17, 24

Notes:

(mg/L) milligrams per liter = 1,000 micrograms per liter (ug/L)

(mg/kg) milligrams per kilogram = 1,000 micrograms per kilogram (ug/kg)

J The value is an estimated quantity (Ref. 49, p. 2).

Q The reported concentration is less than the sample quantitation limit for the specified analyte in the sample (Ref. 49, p. 2).

K Unknown bias (Ref. 49, p. 2). 1 The Method Quantitation Limit (MQL) terminology used by Accutest Laboratory are detection limits which have been adjusted for 

sample aliquot, sample volume, and dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Section 1.1; Ref. 24, p. 4; 

Ref. 26).

2 All laboratory data collected during EPA emergency response activities were validated by an EPA START-3 chemist in accordance 

with EPA Quality Assurance/Quality Control Guidance for Removal Activities, OSWER Directive 9360.4-01 for definitive data use 

objectives and were found to be usable for the intended purpose. Data for target analytes meet the definitive data quality objective 

(Ref 49, pp. 5, 13, 21, 31). 3 These concentrations reported from the TCLP Leachate of the sample.
Source Characterization - Source 3

HRS Documentation Record 31 US Oil Recovery

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2.4.2 Hazardous Waste Quantity

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1 Tier A: Hazardous Constituent Quantity - Not Evaluated (NE)

The information available is not sufficient to determine with reasonable confidence a hazardous 

constituent quantity for Source 3 – Secondary Containment and Truck Bay Sumps (Ref. 1, Section 

2.4.2.1.1). Scoring proceeds to the evaluation of Tier B, hazardous wastestream quantity (Ref. 1, 

Section 2.4.2.1.2).

2.4.2.1.2 Tier B: Hazardous Wastestream Quantity - Not Evaluated (NE)

The information available is not sufficient to determine a hazardous wastestream quantity with 

reasonable confidence for Source 3 (Ref. 1, Section 2.4.2.1.2). Scoring proceeds to the evaluation of 

Tier C, volume (Ref. 1, Section 2.4.2.1.3).

2.4.2.1.3 Tier C: Volume

The volume of the secondary containment structures and truck bay sumps was determined by 

measurements obtained by using GIS software. The depth was determined on site by field personnel. 

The truck bay sumps measure 75 feet x 22 feet x 2 feet (Attachment A, Figure A-2A; Ref. 46). The 

Tier C equation for assigning a value for volumes of a source type “Surface Impoundments” is V/2.5

(Ref. 1, Table 2-5).

Truck Bay Sumps – 75 x 22 x 2 = 3,300 cubic feet

Total = 3,300 cubic feet

3,300 cubic feet / 27 cubic feet per 1 cubic yard = 122.222 cubic yards

Volume of source (cubic yards): 122.222

Volume Assigned Value = 122.222/2.5

Volume Assigned Value = 48.889

2.4.2.1.4 Tier D: Area - Not Evaluated (NE)

Tier C, volume, has been determined; therefore, the value assigned for Tier D is not evaluated (Ref. 1, 

Section 2.4.2.1.4). 

Area Assigned Value = 0

2.4.2.1.5

Per the HRS, the highest of the values assigned to the source for hazardous constituent quantity (Tier 

A), hazardous wastestream quantity (Tier B), volume (Tier C), and area (Tier D) should be assigned as 

Source Hazardous Waste Quantity Value
Source Characterization - Source 3

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the source hazardous waste quantity value (Ref. 1, Section 2.4.2.1.5).

Tier Evaluated Source 3 Values

A Not Evaluated

B Not Evaluated

C 48.889

D 0

Source Hazardous Waste Quantity Value: 48.889
Source Characterization - Source 4

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SOURCE DESCRIPTION

2.2 Source Characterization

Source Description: Source 4 – MCC Surface Impoundments

The surface impoundments at the MCC property include the gravity thickener, digesters, clarifiers, 

chorine contact tank, and the headworks (also referred to as the oil water separator). These structures 

are shown on Attachment A, Figure A-2B. 

The property at 200 N. Richey Street once belonged to the City of Pasadena Vince Bayou WWTP. 

The old plant had been designed and used to treat domestic wastewater. Structures of the old WWTP 

have been converted by MCC Recycling, which is owned by USOR, into oily and organic wastewater 

treatment and storage units (Ref. 12, p. 5). These structures were not designed to store waste, and 

TCEQ required USOR to determine whether the structures were structurally sound and capable of 

functioning for the purpose of wastewater treatment. This testing was never completed (Ref. 12, p. 6). 

During TCEQ investigations conducted in May and June of 2009, it was noted that the structures at 

200 N. Richey Street located on the west side of Vince Bayou were in use except for the headworks 

(also known as oil water separator). At the east plant, the old clarifier, oxygen activated sludge tank, 

oxygen digesters, and final clarifiers were being used as wastewater storage vessels (Ref. 12, p. 7). 

On 11 March 2011, EPA START contractors collected measurements of the various surface 

impoundments located at the 200 N. Richey Street property. The diameter, depth, and liquid levels 

were measured for the gravity thickener, aerobic digester, aeration basin (final clarifier), primary 

clarifier, clarifiers #1 and #2, chlorine contact tank, oxygen activated sludge tank, oxygen digesters #1 

and #2, lift stations 1 and 3, and the headworks (also known as oil water separator) (Ref. 13, pp. 1-4). 

The MCC surface impoundments are aggregated together because they are similar source types (opentop concrete structures), all received wastewater from the USOR property, have similar containment, 

affect same targets, contain similar substances (as will be shown below) and are in the same watershed.

Source Type

The waste contents are in various surface impoundments and, as such, the source type for Source 4 is 

“Surface Impoundments” (Ref. 1, Table 2-5).

Source Location

The MCC surface impoundments are located throughout the 200 N. Richey Street property and are 

shown on Attachment A, Figure A-2B. 

The contents of each reservoir are exposed to precipitation and surface water (through flooding). 

Agencies including EPA, TCEQ, and HCPHES have documented multiple spills from the wastewater 

Source Containment

Release To Surface Water
Source Characterization - Source 4

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treatment property that migrated into Vince Bayou (Ref. 5, pp. 19-20, 62-63, 78, 90-92, 130-131; Ref. 

6, pp. 15-16, 18-19, 74, 81, 83-84, 86-87, 89-90, 284, 287, 295-296, 649-650, 664-665; Ref. 8, p. 8; 

Ref. 18, pp. 3-6, 11). EPA and TCEQ documented that, during several spills in 2009, there was a lack 

of spill prevention containment measures at the site (Ref. 6, p. 14, 326). Evidence of hazardous 

substance migration from Source 4 is documented below.

• In June, 2008 personnel with the TCEQ and HCPES responded to a release of wastewater 

from the west side lift station that was flowing onto the ground and then entering Vince 

Bayou (Ref. 6, pp. 15, 649, 650).

• MCC failed to prevent unpermitted discharges on 15 May, 18 May, 20 May, 26 May, 29 

May, and 8 June, 2009 into Vince Bayou. The discharge that was observed on 18 May 2009 

was from the chlorine contact chamber. The other discharges were due to spills (Ref. 6, p. 

325). 

• In January 2010, wastewater was discharging from the property from the old chlorine 

contact tank flow measurement channel to Vince Bayou from two unpermitted outfalls (Ref. 

6, p. 18, 664-665).

• In July 2010, EPA noted an overflow of oily waste at the east plant lift station (also known 

as Lift Station #1), and leaking of pipes onto vegetation and soil (Ref. 6, pp. 18, 87, 89-90).

• In July 2010, liquid from the chlorine contact chamber was surfacing from cracks in a 

concrete road near the northwest corner of the chlorine contact chamber. The liquid was 

running across the concrete road, onto the ground, and into Vince Bayou near the northwest 

corner of the east plant. The release was stopped by pumping liquid from the chlorine 

contact chamber into frac-tanks (Ref. 6, pp. 19, 74, 81, 83-84, 86, 284, 287).

 

A containment value of 10 was selected for Source 4 based on the evidence of hazardous substance 

migration from the source surface impoundments and the lack of spill prevention containment 

measures at the site (Ref. 1, Table 4-2).

Containment Value: 10

2.4.1 Hazardous Substances

On 12 July 2010 as part of EPA’s emergency response activities, EPA START-3 collected the 

following eight samples from the surface impoundments located at 200 N. Richey Street: sample 

MCC-WW03 was collected from Oxygen Digester #2; sample MCC-WW04 was collected from 

Oxygen Digester #1; sample MCC-WW05 was collected from clarifier #2; samples MCC-WW06 and 

MCC-WW07 were collected from clarifier #1; sample MCC-WW08 was collected from the Primary 

Clarifier; sample MCC-WW09 was collected from the Final Clarifier; and MCC-WW10 was collected 

from the headworks (also known as oil water separator) (Ref. 27, pp. 39-41). The samples were hand 

delivered to Accutest Laboratories located in Houston, Texas. The samples were analyzed for VOCs 

by SW846 8260B, SVOCs by SW846 8270C, and TAL metals with mercury by SW846 6010B/7470A 

(Ref. 22, pp. 4, 5).

As part of the supplemental sampling conducted at the USOR site on 01 through 04 March 2011, EPA 

START-3 collected waste samples from two surface impoundments located on-site. One sample was 

collected from the gravity thickener (SL-01), and one sample was collected from the chlorine contact 

tank (WW-01). The samples were analyzed for VOCs and SVOCs by CLP OLM04.2 and for TAL 
Source Characterization - Source 4

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metals and mercury by CLP ISM05.3 by the EPA Region 6 Environmental Services Branch 

Laboratory (Ref. 24, pp. 123-128, 159-164,325. 

Analytical evidence of the contamination in waste source samples associated with the MCC surface 

impoundments (classified as source type “Tanks and Containers Other Than Drums”) located on the 

USOR site at the 200 N. Richey property is summarized in the following table. 

Hazardous

Substance

Evidence

Sample References

ID Concentration RL/MQL Units 1

EPA Emergency Response Activities – July 2010

Acetone

2

MCC-WW03-11-100712 0.777 0.050 mg/L Ref. 22, pp. 7, 56; Ref. 23, pp. 1,6

Carbon disulfide MCC-WW03-11-100712 0.0176 0.0020 mg/L Ref. 22, pp. 7, 56; Ref. 23, pp. 1,6

Ethylbenzene MCC-WW03-11-100712 0.00098 JQ 0.0020 mg/L Ref. 22, pp. 7, 56; Ref. 23, pp. 1,6

4-Methyl-2-pentanone MCC-WW03-11-100712 0.0509 JK 0.010 mg/L Ref. 22, pp. 7, 56; Ref. 23, pp. 1,6

Methyl ethyl ketone MCC-WW03-11-100712 0.186 JK 0.010 mg/L Ref. 22, pp. 7, 56; Ref. 23, pp. 1,6

Toluene MCC-WW03-11-100712 0.0042 0.0020 mg/L Ref. 22, pp. 7, 56; Ref. 23, pp. 1,6

Xylene (total) MCC-WW03-11-100712 0.0023 JQ 0.0060 mg/L Ref. 22, pp. 8, 56; Ref. 23, pp. 1,7

Benzoic acid MCC-WW03-11-100712 0.586 0.058 mg/L Ref. 22, pp. 9, 56; Ref. 23, pp. 1,27

2-Methylphenol MCC-WW03-11-100712 0.0618 0.029 mg/L Ref. 22, pp. 9, 56; Ref. 23, pp. 1,27

3&4-Methylphenol MCC-WW03-11-100712 0.519 0.029 mg/L Ref. 22, pp. 9, 56; Ref. 23, pp. 1,27

Phenol MCC-WW03-11-100712 0.499 0.029 mg/L Ref. 22, pp. 9, 56; Ref. 23, pp. 1,27

bis(2-Ethylhexyl)phthalate MCC-WW03-11-100712 0.0107 JQ 0.029 mg/L Ref. 22, pp. 10, 56; Ref. 23, pp. 1,28

Antimony MCC-WW03-11-100712 0.0027 JQ 0.0050 mg/L Ref. 22, pp. 12, 56; Ref. 23, pp. 1,56

Arsenic MCC-WW03-11-100712 0.0065 0.0050 mg/L Ref. 22, pp. 12, 56; Ref. 23, pp. 1,56

Barium MCC-WW03-11-100712 0.0102 JQ 0.20 mg/L Ref. 22, pp. 12, 56; Ref. 23, pp. 1,56

Chromium MCC-WW03-11-100712 0.0026 JQ 0.010 mg/L Ref. 22, pp. 12, 56; Ref. 23, pp. 1,56

Cobalt MCC-WW03-11-100712 0.0036 0.050 mg/L Ref. 22, pp. 12, 56; Ref. 23, pp. 1,56

Lead MCC-WW03-11-100712 0.0049 0.0030 mg/L Ref. 22, pp. 12, 56; Ref. 23, pp. 1,56

Manganese MCC-WW03-11-100712 0.0225 0.015 mg/L Ref. 22, pp. 12, 56; Ref. 23, pp. 1,56

Nickel MCC-WW03-11-100712 0.0675 0.040 mg/L Ref. 22, pp. 12, 56; Ref. 23, pp. 1,56

Selenium MCC-WW03-11-100712 0.0012 JQK 0.0050 mg/L Ref. 22, pp. 12, 56; Ref. 23, pp. 1,56

Vanadium MCC-WW03-11-100712 0.0018 JQ 0.050 mg/L Ref. 22, pp. 12, 56; Ref. 23, pp. 1,56

Zinc MCC-WW03-11-100712 0.055 JK 0.020 mg/L Ref. 22, pp. 12, 56; Ref. 23, pp. 1,56

Acetone MCC-WW04-11-100712 0.382 0.050 mg/L Ref. 22, pp 13, 56; Ref. 23, pp. 1,8

Carbon disulfide MCC-WW04-11-100712 0.0091 0.0020 mg/L Ref. 22, pp 13, 56; Ref. 23, pp. 1,8

4-Methyl-2-pentanone MCC-WW04-11-100712 0.0606 JK 0.010 mg/L Ref. 22, pp 13, 56; Ref. 23, pp. 1,8

Methyl ethyl ketone MCC-WW04-11-100712 0.160 JK 0.010 mg/L Ref. 22, pp 13, 56; Ref. 23, pp. 1,8

Toluene MCC-WW04-11-100712 0.0015 JQ 0.0020 mg/L Ref. 22, pp 13, 56; Ref. 23, pp. 1, 8

Benzoic acid MCC-WW04-11-100712 0.173 0.055 mg/L Ref. 22, pp. 15, 56; Ref. 23, pp. 1, 30

2-Methylphenol MCC-WW04-11-100712 0.0236 JQ 0.027 mg/L Ref. 22, pp. 15, 56; Ref. 23, pp. 1, 30

3&4-Methylphenol MCC-WW04-11-100712 0.0695 0.027 mg/L Ref. 22, pp. 15, 56; Ref. 23, pp. 1, 30
Source Characterization - Source 4

HRS Documentation Record 36 US Oil Recovery

TXN000607093

Hazardous

Substance

Evidence

Sample References

ID Concentration RL/MQL Units 1

Phenol MCC-WW04-11-100712 0.0814 0.027 mg/L Ref. 22, pp. 15, 56; Ref. 23, pp. 1, 30

bis(2-Ethylhexyl)phthalate MCC-WW04-11-100712 0.0097 JQ 0.027 mg/L Ref. 22, pp. 16, 56; Ref. 23, pp. 1, 31

Antimony MCC-WW04-11-100712 0.0053 0.0050 mg/L Ref. 22, pp.18, 56; Ref. 23, pp. 1, 57

Arsenic MCC-WW04-11-100712 0.0068 0.0050 mg/L Ref. 22, pp.18, 56; Ref. 23, pp. 1, 57

Barium MCC-WW04-11-100712 0.0090 JQ 0.20 mg/L Ref. 22, pp.18, 56; Ref. 23, pp. 1, 57

Chromium MCC-WW04-11-100712 0.0030 JQ 0.010 mg/L Ref. 22, pp.18, 56; Ref. 23, pp. 1, 57

Cobalt MCC-WW04-11-100712 0.0058 JQ 0.050 mg/L Ref. 22, pp.18, 56; Ref. 23, pp. 1, 57

Lead MCC-WW04-11-100712 0.0071 0.0030 mg/L Ref. 22, pp.18, 56; Ref. 23, pp. 1, 57

Manganese MCC-WW04-11-100712 0.0144 JQ 0.015 mg/L Ref. 22, pp.18, 56; Ref. 23, pp. 1, 57

Nickel MCC-WW04-11-100712 0.0903 0.040 mg/L Ref. 22, pp.18, 56; Ref. 23, pp. 1, 57

Selenium MCC-WW04-11-100712 0.0028 JQK 0.0050 mg/L Ref. 22, pp.18, 56; Ref. 23, pp. 1, 57

Vanadium MCC-WW04-11-100712 0.0023 JQ 0.050 mg/L Ref. 22, pp.18, 56; Ref. 23, pp. 1, 57

Zinc MCC-WW04-11-100712 0.0638 JK 0.020 mg/L Ref. 22, pp.18, 56; Ref. 23, pp. 1, 57

Acetone MCC-WW05-11-100712 0.137 0.050 mg/L Ref. 22, pp. 19, 56; Ref. 23, pp. 1, 10

Carbon disulfide MCC-WW05-11-100712 0.0089 0.0020 mg/L Ref. 22, pp. 19, 56; Ref. 23, pp. 1, 10

Methyl ethyl ketone MCC-WW05-11-100712 0.0288 JK 0.010 mg/L Ref. 22, pp. 19, 56; Ref. 23, pp. 1, 10

Toluene MCC-WW05-11-100712 0.00061 JQ 0.0020 mg/L Ref. 22, pp. 19, 56; Ref. 23, pp. 1, 10

Xylene (total) MCC-WW05-11-100712 0.0026JQ 0.0060 mg/L Ref. 22, pp. 20, 56; Ref. 23, pp. 1, 11

Benzoic acid MCC-WW05-11-100712 0.357 0.055 mg/L Ref. 22, pp. 21, 56; Ref. 23, pp. 1,33

2-Methylphenol MCC-WW05-11-100712 0.0116 JQ 0.027 mg/L Ref. 22, pp. 21, 56; Ref. 23, pp. 1, 33

3&4-Methylphenol MCC-WW05-11-100712 0.157 0.027 mg/L Ref. 22, pp. 21, 56; Ref. 23, pp. 1, 33

Phenol MCC-WW05-11-100712 0.0259 JQ 0.027 mg/L Ref. 22, pp. 21, 56; Ref. 23, pp. 1, 33

Arsenic MCC-WW05-11-100712 0.0094 0.0050 mg/L Ref. 22, pp. 24, 56; Ref. 23, pp. 1, 58

Chromium MCC-WW05-11-100712 0.0079 JQ 0.010 mg/L Ref. 22, pp. 24, 56; Ref. 23, pp. 1, 58

Cobalt MCC-WW05-11-100712 0.0030 JQ 0.050 mg/L Ref. 22, pp. 24, 56; Ref. 23, pp. 1, 58

Lead MCC-WW05-11-100712 0.0064 0.0030 mg/L Ref. 22, pp. 24, 56; Ref. 23, pp. 1, 58

Manganese MCC-WW05-11-100712 0.0195 0.0015 mg/L Ref. 22, pp. 24, 56; Ref. 23, pp. 1, 58

Nickel MCC-WW05-11-100712 0.114 0.040 mg/L Ref. 22, pp. 24, 56; Ref. 23, pp. 1, 58

Selenium MCC-WW05-11-100712 0.0017 JQK 0.0050 mg/L Ref. 22, pp. 24, 56; Ref. 23, pp. 1, 58

Vanadium MCC-WW05-11-100712 0.0051 JQ 0.050 mg/L Ref. 22, pp. 24, 56; Ref. 23, pp. 1, 58

Zinc MCC-WW05-11-100712 0.142 JK 0.020 mg/L Ref. 22, pp. 24, 56; Ref. 23, pp. 1, 58

Acetone MCC-WW06-11-100712 0.387 0.050 mg/L Ref. 22, pp. 25, 57; Ref. 23, pp. 1, 12

Benzene MCC-WW06-11-100712 0.0017 JQ 0.0020 mg/L Ref. 22, pp. 25, 57; Ref. 23, pp. 1, 12

Carbon disulfide MCC-WW06-11-100712 0.0097 0.0020 mg/L Ref. 22, pp. 25, 57; Ref. 23, pp. 1, 12

Ethylbenzene MCC-WW06-11-100712 0.00079 JQ 0.0020 mg/L Ref. 22, pp. 25, 57; Ref. 23, pp. 1, 12

4-Methyl-2-pentanone MCC-WW06-11-100712 0.013 JK 0.010 mg/L Ref. 22, pp. 25, 57; Ref. 23,pp. 1, 12

Methyl ethyl ketone MCC-WW06-11-100712 0.078 JK 0.010 mg/L Ref. 22, pp. 25, 57; Ref. 23, pp. 1, 12

Toluene MCC-WW06-11-100712 0.0015 JQ 0.0020 mg/L Ref. 22, pp. 25, 57; Ref. 23, pp. 1, 12
Source Characterization - Source 4

HRS Documentation Record 37 US Oil Recovery

TXN000607093

Hazardous

Substance

Evidence

Sample References

ID Concentration RL/MQL Units 1

Xylene (total) MCC-WW06-11-100712 0.0032 JQ 0.0060 mg/L Ref. 22, pp. 26, 57; Ref. 23, pp. 1, 13

Benzoic acid MCC-WW06-11-100712 0.366 0.055 mg/L Ref. 22, pp. 27, 57; Ref. 23, pp. 1, 36

2-Methylphenol MCC-WW06-11-100712 0.0299 0.027 mg/L Ref. 22, pp. 27, 57; Ref. 23, pp. 1, 36

3&4-Methylphenol MCC-WW06-11-100712 0.510 0.027 mg/L Ref. 22, pp. 27, 57; Ref. 23, pp. 1, 36

Phenol MCC-WW06-11-100712 0.142 0.027 mg/L Ref. 22, pp. 27, 57; Ref. 23, pp. 1, 36

Arsenic MCC-WW06-11-100712 0.0077 0.0050 mg/L Ref. 22, pp. 30, 57; Ref. 23, pp. 1, 59

Barium MCC-WW06-11-100712 0.0058 JQ 0.20 mg/L Ref. 22, pp. 30, 57; Ref. 23, pp. 1, 59

Chromium MCC-WW06-11-100712 0.0070 JQ 0.010 mg/L Ref. 22, pp. 30, 57; Ref. 23, pp. 1, 59

Cobalt MCC-WW06-11-100712 0.0026 JQ 0.050 mg/L Ref. 22, pp. 30, 57; Ref. 23, pp. 1, 59

Lead MCC-WW06-11-100712 0.0069 0.0030 mg/L Ref. 22, pp. 30, 57; Ref. 23, pp. 1, 59

Manganese MCC-WW06-11-100712 0.0483 0.015 mg/L Ref. 22, pp. 30, 57; Ref. 23, pp. 1, 59

Nickel MCC-WW06-11-100712 0.0902 0.040 mg/L Ref. 22, pp. 30, 57; Ref. 23, pp. 1, 59

Selenium MCC-WW06-11-100712 0.0027 JQK 0.0050 mg/L Ref. 22, pp. 30, 57; Ref. 23, pp. 1, 59

Vanadium MCC-WW06-11-100712 0.0055 JQ 0.050 mg/L Ref. 22, pp. 30, 57; Ref. 23, pp. 1, 59

Zinc MCC-WW06-11-100712 0.140 JK 0.020 mg/L Ref. 22, pp. 30, 57; Ref. 23, pp. 1, 59

Acetone MCC-WW07-12-100712 0.450 0.050 mg/L Ref. 22, pp. 31, 57; Ref. 23, pp. 1, 14

Benzene MCC-WW07-12-100712 0.0019 JQ 0.0020 mg/L Ref. 22, pp. 31, 57; Ref. 23, pp. 1, 14

Carbon disulfide MCC-WW07-12-100712 0.0082 0.0020 mg/L Ref. 22, pp. 31, 57; Ref. 23, pp. 1, 14

Ethylbenzene MCC-WW07-12-100712 0.0012 JQ 0.0020 mg/L Ref. 22, pp. 31, 57; Ref. 23, pp. 1, 14

4-Methyl-2-pentanone MCC-WW07-12-100712 0.0152 0.010 mg/L Ref. 22, pp. 31, 57; Ref. 23, pp. 1, 14

Methyl ethyl ketone MCC-WW07-12-100712 0.0932 0.010 mg/L Ref. 22, pp. 31, 57; Ref. 23, pp. 1, 14

Toluene MCC-WW07-12-100712 0.002 0.0020 mg/L Ref. 22, pp. 31, 57; Ref. 23, pp. 1, 14

Xylene (total) MCC-WW07-12-100712 0.0043 JQ 0.006 mg/L Ref. 22, pp. 32, 57; Ref. 23, pp. 1, 15

Benzoic acid MCC-WW07-12-100712 0.321 0.055 mg/L Ref. 22, pp. 33, 57; Ref. 23, pp. 1, 39

2-Methylphenol MCC-WW07-12-100712 0.0232 JQ 0.027 mg/L Ref. 22, pp. 33, 57; Ref. 23, pp. 1, 39

3&4-Methylphenol MCC-WW07-12-100712 0.362 0.027 mg/L Ref. 22, pp. 33, 57; Ref. 23, pp. 1, 39

Phenol MCC-WW07-12-100712 0.108 0.027 mg/L Ref. 22, pp. 33, 57; Ref. 23, pp. 1, 39

bis(2-Ethylhexyl)phthalate MCC-WW07-12-100712 0.012 JQ 0.027 mg/L Ref. 22, pp. 34, 57; Ref. 23, pp. 1, 40

Naphthalene MCC-WW07-12-100712 0.0068 JQ 0.027 mg/L Ref. 22, pp. 34, 57; Ref. 23,pp. 1, 40

Arsenic MCC-WW07-12-100712 0.0082 0.0050 mg/L Ref. 22, pp. 36, 57; Ref. 23, pp. 1, 60

Barium MCC-WW07-12-100712 0.0047 JQ 0.20 mg/L Ref. 22, pp. 36, 57; Ref. 23, pp. 1, 60

Chromium MCC-WW07-12-100712 0.0069 JQ 0.010 mg/L Ref. 22, pp. 36, 57; Ref. 23, pp. 1, 60

Cobalt MCC-WW07-12-100712 0.0025 JQ 0.050 mg/L Ref. 22, pp. 36, 57; Ref. 23, pp. 1, 60

Lead MCC-WW07-12-100712 0.0069 0.0030 mg/L Ref. 22, pp. 36, 57; Ref. 23, pp. 1, 60

Manganese MCC-WW07-12-100712 0.0462 0.015 mg/L Ref. 22, pp. 36, 57; Ref. 23, pp. 1, 60

Nickel MCC-WW07-12-100712 0.0901 0.040 mg/L Ref. 22, pp. 36, 57; Ref. 23, pp. 1, 60

Selenium MCC-WW07-12-100712 0.0013 JQK 0.0050 mg/L Ref. 22, pp. 36, 57; Ref. 23, pp. 1, 60

Vanadium MCC-WW07-12-100712 0.0055 JQ 0.050 mg/L Ref. 22, pp. 36, 57; Ref. 23, pp. 1, 60
Source Characterization - Source 4

HRS Documentation Record 38 US Oil Recovery

TXN000607093

Hazardous

Substance

Evidence

Sample References

ID Concentration RL/MQL Units 1

Zinc MCC-WW07-12-100712 0.139 JK 0.020 mg/L Ref. 22, pp. 36, 57; Ref. 23, pp. 1, 60

Acetone MCC-WW08-11-100712 18.5 JL 1.30 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

Benzene MCC-WW08-11-100712 3.13 JL 0.050 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

Chloroform MCC-WW08-11-100712 0.0177 JL 0.010 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

Carbon disulfide MCC-WW08-11-100712 0.032 JL 0.010 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

1,2-Dichloroethane MCC-WW08-11-100712 0.991 JL 0.050 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

1,2-Dichloropropane MCC-WW08-11-100712 0.0053 JQL 0.010 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

Ethylbenzene MCC-WW08-11-100712 1.92 JL 0.050 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

4-Methyl-2-pentanone MCC-WW08-11-100712 2.10 JL 0.050 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

Methylene chloride MCC-WW08-11-100712 0.669 JL 0.010 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

Methyl ethyl ketone MCC-WW08-11-100712 2.75 JL 0.050 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

Tetrachloroethylene MCC-WW08-11-100712 0.0409 JL 0.010 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

Toluene MCC-WW08-11-100712 3.38 JL 0.050 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

Trichloroethylene MCC-WW08-11-100712 0.0479 JL 0.010 mg/L Ref. 22, pp. 37, 57; Ref. 23, pp. 1, 16

Xylene (total) MCC-WW08-11-100712 8.77 JL 0.150 mg/L Ref. 22, pp. 38, 57; Ref. 23, pp. 1, 17

3&4-Methylphenol MCC-WW08-11-100712 1.34 1.1 mg/L Ref. 22, pp. 39, 57; Ref. 23, pp. 1, 42

Acenapthene MCC-WW08-11-100712 0.847 JQ 1.1 mg/L Ref. 22, pp. 39, 57; Ref. 23, pp. 1, 42

Di-n-butyl phthalate MCC-WW08-11-100712 0.377 JQ 1.1 mg/L Ref. 22, pp. 40, 57; Ref. 23, pp. 1, 43

bis(2-Ethylhexyl)phthalate MCC-WW08-11-100712 0.926 JQ 1.1 mg/L Ref. 22, pp. 40, 57; Ref. 23, pp. 1, 43

Fluorene MCC-WW08-11-100712 0.465 JQ 1.1 mg/L Ref. 22, pp. 40, 57; Ref. 23, pp. 1, 43

2-Methylnaphthalene MCC-WW08-11-100712 9.44 1.1 mg/L Ref. 22, pp. 40, 57; Ref. 23, pp. 1, 43

Naphthalene MCC-WW08-11-100712 32.0 5.4 mg/L Ref. 22, pp. 40, 57; Ref. 23, pp. 1, 43

Phenanthrene MCC-WW08-11-100712 0.735 JQ 1.1 mg/L Ref. 22, pp. 40, 57; Ref. 23, pp. 1, 43

Antimony MCC-WW08-11-100712 0.637 0.0050 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Arsenic MCC-WW08-11-100712 0.118 0.0050 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Barium MCC-WW08-11-100712 19.5 0.20 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Cadmium MCC-WW08-11-100712 0.0155 0.0040 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Chromium MCC-WW08-11-100712 0.932 0.010 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Cobalt MCC-WW08-11-100712 0.324 0.050 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Copper MCC-WW08-11-100712 2.56 0.025 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Lead MCC-WW08-11-100712 1.11 0.0030 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Manganese MCC-WW08-11-100712 1.91 0.015 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Mercury MCC-WW08-11-100712 0.264 0.020 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Nickel MCC-WW08-11-100712 1.89 0.040 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Selenium MCC-WW08-11-100712 0.0129 JL 0.0050 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Silver MCC-WW08-11-100712 0.0227 0.010 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Vanadium MCC-WW08-11-100712 0.548 0.050 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61

Zinc MCC-WW08-11-100712 35.4 JK 0.10 mg/L Ref. 22, pp. 42, 57; Ref. 23, pp. 1, 61
Source Characterization - Source 4

HRS Documentation Record 39 US Oil Recovery

TXN000607093

Hazardous

Substance

Evidence

Sample References

ID Concentration RL/MQL Units 1

Acetone MCC-WW09-11-10712 0.0783 JK 0.050 mg/L Ref. 22, pp. 43, 57 Ref. 23, pp. 1, 18

Carbon disulfide MCC-WW09-11-10712 0.0012 JQL 0.0020 mg/L Ref. 22, pp. 43, 57 Ref. 23, pp. 1, 18

Ethylbenzene MCC-WW09-11-10712 0.00092 JQL 0.0020 mg/L Ref. 22, pp. 43, 57 Ref. 23, pp. 1, 18

Methyl ethyl ketone MCC-WW09-11-10712 0.0087 JQL 0.010 mg/L Ref. 22, pp. 43, 57; Ref. 23, pp. 1, 18

Toluene MCC-WW09-11-10712 0.00081 JQL 0.0020 mg/L Ref. 22, pp. 43, 57 Ref. 23, pp. 1, 18

Xylene (total) MCC-WW09-11-10712 0.004 JQL 0.0060 mg/L Ref. 22, pp. 44, 57; Ref. 23, pp. 1, 19

Chrysene MCC-WW09-11-10712 0.0061 JQ 0.027 mg/L Ref. 22, pp. 45, 57; Ref. 23, pp. 1, 45

bis(2-Ethylhexyl)phthalate MCC-WW09-11-10712 0.0337 0.027 mg/L Ref. 22, pp. 46, 57 Ref. 23, pp. 1, 46

Pyrene MCC-WW09-11-10712 0.0105 0.027 mg/L Ref. 22, pp. 46, 57 Ref. 23, pp. 1, 46

Antimony MCC-WW09-11-10712 0.0130 0.0050 mg/L Ref. 22, pp. 48, 58; Ref. 23, pp. 1, 62

Arsenic MCC-WW09-11-10712 0.0083 0.0050 mg/L Ref. 22, pp. 48, 58; Ref. 23, pp. 1, 62

Barium MCC-WW09-11-10712 0.0056 JQ 0.20 mg/L Ref. 22, pp. 48, 58; Ref. 23, pp. 1, 62

Chromium MCC-WW09-11-10712 0.0080 JQ 0.010 mg/L Ref. 22, pp. 48, 58; Ref. 23, pp. 1, 62

Cobalt MCC-WW09-11-10712 0.0183 JQ 0.050 mg/L Ref. 22, pp. 48, 58; Ref. 23, pp.1, 62

Lead MCC-WW09-11-10712 0.0091 0.0030 mg/L Ref. 22, pp. 48, 58; Ref. 23, pp. 1, 62

Manganese MCC-WW09-11-10712 0.0946 0.015 mg/L Ref. 22, pp. 48, 58; Ref. 23, pp. 1, 62

Nickel MCC-WW09-11-10712 0.271 0.040 mg/L Ref. 22, pp. 48, 58; Ref. 23, pp. 1, 62

Selenium MCC-WW09-11-10712 0.0020 JQK 0.0050 mg/L Ref. 22, pp. 48, 58; Ref. 23, pp. 1, 62

Vanadium MCC-WW09-11-10712 0.0148 JQ 0.050 mg/L Ref. 22, pp. 48, 58; Ref. 23, pp. 1, 62

Zinc MCC-WW09-11-10712 0.0529 JK 0.020 mg/L Ref. 22, pp. 48, 58; Ref. 23, pp. 1, 62

Bis(2-Ethylhexyl)phthalate MCC-WW10-11-100712 0.0018 JQ 0.0050 mg/L Ref. 22, pp.52, 58; Ref. 23, pp. 1, 49

Antimony MCC-WW10-11-100712 0.0293 0.0050 mg/L Ref. 22, pp. 54, 58; Ref. 23, pp. 1, 63

Barium MCC-WW10-11-100712 0.101 JQ 0.20 mg/L Ref. 22, pp. 54, 58; Ref. 23, pp. 1, 63

Manganese MCC-WW10-11-100712 0.134 0.015 mg/L Ref. 22, pp. 54, 58; Ref. 23, pp. 1, 63

Nickel MCC-WW10-11-100712 0.0016 JQ 0.040 mg/L Ref. 22, pp. 54, 58; Ref. 23, pp. 1, 63

Selenium MCC-WW10-11-100712 0.0014 JQK 0.0050 mg/L Ref. 22, pp. 54, 58; Ref. 23, pp. 1, 63

Zinc MCC-WW10-11-100712 0.0762 JK 0.020 mg/L Ref. 22, pp. 54, 58; Ref. 23, pp. 1, 63

EPA Supplemental Sampling Activities – March 2011 

Carbon disulfide WW-01-00-11-20110303 0.0111 0.002 mg/L Ref. 24, pp. 159,325 ; Ref. 28, p. 73

Acetone WW-01-00-11-20110303 2.83 1.0 mg/L Ref. 24, pp. 159,325 ; Ref. 28, p. 73

Methyl acetate WW-01-00-11-20110303 0.0044 J 0.002 mg/L Ref. 24, pp. 159,325 ; Ref. 28, p. 73

Methyl tert-butyl ether WW-01-00-11-20110303 0.0025 0.002 mg/L Ref. 24, pp. 159,325 ; Ref. 28, p. 73

2-Butanone WW-01-00-11-20110303 0.0812 0.005 mg/L Ref. 24, pp. 159,325 ; Ref. 28, p. 73

Benzene WW-01-00-11-20110303 0.0056 J 0.002 mg/L Ref. 24, pp. 159,325 ; Ref. 28, p. 73

4-Methyl2-pentanone WW-01-00-11-20110303 0.0274 0.005 mg/L Ref. 24, pp. 160, 325 ; Ref. 28, p. 73

Toluene WW-01-00-11-20110303 0.0335 J 0.002 mg/L Ref. 24, pp. 160, 325 ; Ref. 28, p. 73

Ethylbenzene WW-01-00-11-20110303 0.0621 J 0.002 mg/L Ref. 24, pp. 160, 325 ; Ref. 28, p. 73

meta-/para-Xylene WW-01-00-11-20110303 0.288 J 0.040 mg/L Ref. 24, pp. 160, 325 ; Ref. 28, p. 73
Source Characterization - Source 4

HRS Documentation Record 40 US Oil Recovery

TXN000607093

Hazardous

Substance

Evidence

Sample References

ID Concentration RL/MQL Units 1

ortho-Xylene WW-01-00-11-20110303 0.093 J 0.002 mg/L Ref. 24, pp. 160, 325 ; Ref. 28, p. 73

Benzoic acid WW-01-00-11-20110303 1.82 J 1.0 mg/L Ref. 24, pp. 161, 325 ; Ref. 28, p. 73

bis(2-Ethylhexyl)phthalate WW-01-00-11-20110303 0.0942 0.05 mg/L Ref. 24, pp. 161, 325 ; Ref. 28, p. 73

Caprolactum WW-01-00-11-20110303 0.080 0.05 mg/L Ref. 24, pp. 161, 325 ; Ref. 28, p. 73

2-Methylphenol WW-01-00-11-20110303 0.0617 0.05 mg/L Ref. 24, pp. 162, 325 ; Ref. 28, p. 73

3&/or4-Methylphenol WW-01-00-11-20110303 0.732 0.05 mg/L Ref. 24, pp. 162, 325 ; Ref. 28, p. 73

Naphthalene WW-01-00-11-20110303 1.45 0.2 mg/L Ref. 24, pp. 162, 325 ; Ref. 28, p. 73

Phenol WW-01-00-11-20110303 0.774 0.05 mg/L Ref. 24, pp. 163, 325 ; Ref. 28, p. 73

Manganese WW-01-00-11-20110303 0.116 0.050 mg/L Ref. 24, pp. 164, 325 ; Ref. 28, p. 73

Methylcyclohexane SL-01-00-81 0.349 0.0998 mg/kg Ref. 24, pp. 123, 325; Ref. 28, p. 72

Toluene SL-01-00-81 0.971 0.0998 mg/kg Ref. 24, pp. 124, 325; Ref. 28, p. 72

Ethylbenzene SL-01-00-81 2.19 0.0998 mg/kg Ref. 24, pp. 124, 325; Ref. 28, p. 72

meta-/para-Xylene SL-01-00-81 15.6 0.2 mg/kg Ref. 24, pp. 124, 325; Ref. 28, p. 72

ortho-Xylene SL-01-00-81 6.87 0.0998 mg/kg Ref. 24, pp. 124, 325; Ref. 28, p. 72

Isopropylbenzene SL-01-00-81 0.429 0.0998 mg/kg Ref. 24, pp. 124, 325; Ref. 28, p. 72

Acenaphthene SL-01-00-81 26.2 9.0 mg/kg Ref. 24, pp. 125, 325; Ref. 28, p. 72

1,1’-Biphenyl SL-01-00-81 52.4 22.5 mg/kg Ref. 24, pp. 125, 325; Ref. 28, p. 72

Bis(2-ethylhexyl)phthalate SL-01-00-81 93.3 22.5 mg/kg Ref. 24, pp. 125, 325; Ref. 28, p. 72

Chrysene SL-01-00-81 31.2 22.5 mg/kg Ref. 24, pp. 126, 325; Ref. 28, p. 72

Di-n-butyl phthalate SL-01-00-81 59.3 22.5 mg/kg Ref. 24, pp. 126, 325; Ref. 28, p. 72

Fluoranthene SL-01-00-81 9.45 9.0 mg/kg Ref. 24, pp. 126, 325; Ref. 28, p. 72

Fluorene SL-01-00-81 28.6 9.0 mg/kg Ref. 24, pp. 126, 325; Ref. 28, p. 72

2-Methylnaphthalene SL-01-00-81 95 9.0 mg/kg Ref. 24, pp. 126, 325; Ref. 28, p. 72

3-&/or4-Methylphenol SL-01-00-81 137 22.5 mg/kg Ref. 24, pp. 126, 325; Ref. 28, p. 72

Naphthalene SL-01-00-81 140 9.0 mg/kg Ref. 24, pp. 126, 325; Ref. 28, p. 72

Phenanthrene SL-01-00-81 35.4 9.0 mg/kg Ref. 24, pp. 127, 325; Ref. 28, p. 72

Pyrene SL-01-00-81 52.2 9.0 mg/kg Ref. 24, pp. 127, 325; Ref. 28, p. 72

Barium SL-01-00-81 190 24.6 mg/kg Ref. 24, pp. 128, 325; Ref. 28, p. 72

Chromium SL-01-00-81 44.7 24.6 mg/kg Ref. 24, pp. 128, 325; Ref. 28, p. 72

Copper SL-01-00-81 105 K 49.2 mg/kg Ref. 24, pp. 128, 325; Ref. 28, p. 72

Manganese SL-01-00-81 87.2 K 12.3 mg/kg Ref. 24, pp. 128, 325; Ref. 28, p. 72

Nickel SL-01-00-81 87.8 49.2 mg/kg Ref. 24, pp. 128, 325; Ref. 28, p. 72

Zinc SL-01-00-81 1,890 49.2 mg/kg Ref. 24, pp. 128, 325; Ref. 28, p. 72

Q The reported concentration is less than the reporting limit for this laboratory but greater than the method detection limit (Ref. 23, p. 

5). For results flagged with a “Q”, the laboratory used the Method Quantitation Limit (MQL) terminology in place of Sample 

Notes:

mg/L) milligrams per liter = 1,000 micrograms per liter (ug/L)

(mg/kg) milligrams per kilogram = 1,000 micrograms per kilogram (ug/kg)

J Identification of analyte is acceptable; the reported value is an estimate (Ref. 24, p. 328).

L Identification of analyte is acceptable; reported value may be biased low (Ref. 24, p. 328).

H Identification of analyte is acceptable; reported value may be biased high (Ref. 24, p.328).
Source Characterization - Source 4

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Quantitation Limit (SQL). No bias indicated (Ref. 23, p. 2). 1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory and the Method Quantitation Limit (MQL) 

terminology used by Accutest Laboratory are both detection limits which have been adjusted for sample aliquot, sample volume, and 

dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Section 1.1 Ref. 24, p. 4; Ref. 26).

2 All laboratory data collected during EPA emergency response activities July 2010 were validated by an EPA START-3 chemist in 

accordance with EPA Quality Assurance/Quality Control Guidance for Removal Activities, OSWER Directive 9360.4-01 for 

definitive data use objectives and were found to be usable for the intended purpose. Data for target analytes meet the definitive data 

quality objective (Ref 23, pp. 5, 26, 55). 

2.4.2 Hazardous Waste Quantity

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1 Tier A: Hazardous Constituent Quantity - Not Evaluated (NE)

The information available is not sufficient to determine with reasonable confidence a hazardous 

constituent quantity for Source 4 - Sumps (Ref. 1, Section 2.4.2.1.1). Scoring proceeds to the 

evaluation of Tier B, hazardous wastestream quantity (Ref. 1, Section 2.4.2.1.2).

2.4.2.1.2 Tier B: Hazardous Wastestream Quantity - Not Evaluated (NE)

The information available is not sufficient to determine with reasonable confidence a hazardous 

wastestream quantity for Source 4 (Ref. 1, Section 2.4.2.1.2). Scoring proceeds to the evaluation of 

Tier C, volume (Ref. 1, Section 2.4.2.1.3).

2.4.2.1.3

Reservoir Name

Tier C: Volume

The quantity volume of the surface impoundments was determined by measurements obtained on-site 

(Ref. 13, pp. 1-4). The surface impoundments and their volumes are as follows (Attachment A, Figure

A-2B; Ref. 13, pp. 1-4):

Location Volume (gallons)

Gravity Thickener Located on eastern side of 200 N. Richey Street

property at southwest corner

10,794

Final Clarifier Located on western side of 200 N. Richey Street

property on east side

293,640

Primary Clarifier Located on western side of 200 N. Richey Street

property on south side

48,937

Clarifier #1 Located on eastern side of 200 N. Richey Street

property on north side

305,624

Clarifier #2 Located on eastern side of 200 N. Richey Street

property on north side

297,141

Chlorine Contact Tank Located on eastern side of 200 N. Richey Street

property on northwest side

143,640

Oxygen Digester #1 Located on eastern side of 200 N. Richey Street

property centrally located south of clarifiers

90,589
Source Characterization - Source 4

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Reservoir Name Location Volume (gallons)

Oxygen Digester #2 Located on eastern side of 200 N. Richey Street

property centrally located south of clarifiers

125,425

Headworks Located on western side of 200 N. Richey Street

property on north side

unknown

Total Reservoir Volume 1,315,790

The volume calculated for the surface impoundments is estimated to be 1,315,790 gallons. The Tier C 

equation for assigning a value for volumes of a source type “Tanks and Containers Other than Drums” 

is V/2.5 (Ref. 1, Table 2-5).

Volume of source (gallons): 1,315,790

1,315,790 gallons/201.97 (gallons per cubic yard) = 6,514.779 cubic yards

Volume Assigned Value = 6,514.779/2.5

Volume Assigned Value = 2,605.912

2.4.2.1.4 Tier D: Area - Not Evaluated (NE)

Tier C, volume, has already been determined; therefore, the value assigned for Tier D is not evaluated 

(Ref. 1, Section 2.4.2.1.4). 

Area Assigned Value = 0

2.4.2.1.5

Tier Evaluated

Source Hazardous Waste Quantity Value

Per the HRS, the highest of the values assigned to the source for hazardous constituent quantity (Tier 

A), hazardous wastestream quantity (Tier B), volume (Tier C), and area (Tier D) should be assigned as 

the source hazardous waste quantity value (Ref. 1, Section 2.4.2.1.5).

Source 4 Values

A Not Evaluated

B Not Evaluated

C 2,605.912

D 0

Source Hazardous Waste Quantity Value: 2,605.912
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SOURCE DESCRIPTION

2.2 Source Characterization

Source Description: Source 5 – Poly Totes (Flammable and Corrosive)

Two hundred twelve 400-gallon poly totes are located within the warehouse of the USOR property at 

400 N. Richey. Of these, 20 totes contain corrosive hazardous waste and 62 totes contain flammable 

hazardous waste located within the Container Storage Area of the warehouse which is not authorized 

to store hazardous waste. The following was also noted during a 15 November 2009 TCEQ 

inspection: leaking containers; containers stored in an unsafe manner; universal waste not stored in 

double rows of containers separate from non-hazardous waste; inadequate aisle space; open containers 

storing waste; and storage of liquid waste (Ref. 8, pp. 8, 139, 144, 145; Ref. 43, pp. 6-10).

As part of the EPA ER activities conducted in July 2010, hazardous categorization was performed on 

the totes within the warehouse (Ref. 5, p. 75; Ref. 7, p. 19). EPA contractors found that the contents 

of the totes were not consistent with their labels. Most of the totes marked with “Universal Waste” 

labels contained flammables and corrosives (Ref. 5, pp. 19, 74-75; Ref. 7, p. 14). EPA contractors 

staged the totes within the warehouse according to their waste streams, and secondary containment 

areas were built to ensure containers were stable and not staged in an unsafe manner (Ref. 7, p. 19).

Source Type

The waste is contained in poly totes and, as such, the source type for Source 5 is “Tanks and 

Containers Other than Drums” (Ref. 1, Table 2-5; Ref. 7, p.19).

Source Location

The totes are currently located within the Container Storage Area of the warehouse on the USOR 

property at 400 N. Richey Street (Ref. 7, p. 19 Figure A-2A). 

Source Containment

Release to Surface Water

Contents of the poly totes are exposed to precipitation and potentially surface water (through flooding 

and were in direct contact with floodwater (Ref. 6, pp. 68, 97, 100, 101, 102, 120, 187, 208, 211). On 

16 November 2009, the TCEQ Region 12 Waste Program conducted an investigation at USOR and 

found unauthorized hazardous waste being stored in the container storage area. The following 

violations were observed in the container storage area: leaking containers; containers stored in an 

unsafe manner; universal waste not stored in double rows of containers; failure to ensure all containers 

of hazardous waste were closed or covered; failure to ensure waste was stored in leak free containers; 

failure to obtain a RCRA permit; and failure to prevent the discharge or imminent threat of discharge 

of industrial solid waste or municipal hazardous waste into the Vince Bayou (Ref. 8, p. 8). EPA 

documented that several of the totes were found in varying states of disrepair with evidence of leakage 

(Ref 7, pp. 18, 25; Ref. 43, pp. 6-10).
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Since the EPA response activities in 2010 have placed the poly totes within secondary containment, a 

containment value of 9 was selected for Source 1 based on the current containment conditions, but the 

site is currently abandoned, and there is no maintenance of the containment area (Ref. 1, Table 4-2).

Containment Value: 9

2.4.1 Hazardous Substances

As part of the EPA supplemental sampling of the USOR site on 01 through 04 March 2011, EPA 

START-3 collected waste samples from two of the poly totes (T0126 and T0212) (Ref. 28, p. 73; Ref. 

44, p. 4). These poly totes were located within the warehouse of the USOR property at 400 N. Richey 

Street (Ref. 28, p. 73). Totes T0126 and T0212 were sampled based on their hazardous categorization 

results and were identified by EPA START-3 as a Non-Flammable Liquid and as a Flammable Solid, 

respectively (Ref. 10, pp. 81, 86). The samples were analyzed for VOCs and SVOCs by CLP 

OLM04.2 and for TAL metals and mercury by CLP ISM05.3 by the EPA Region 6 Environmental 

Services Branch Laboratory (Ref. 28, p. 74; Ref. 24, pp. 183-194, 326). 

Analytical evidence of the contamination in waste source samples associated with Source 5 located on 

the USOR site is summarized in the following table. 

Hazardous

Substance

Evidence

References Sample ID Concentration Reporting 

Limit

Units 1

EPA Supplemental Sampling Activities – March 2011 

Acetone T0126-00-81 4,300 J 2,500 mg/L Ref. 24, pp. 183, 326; Ref. 28, p. 73 

Methylene chloride T0126-00-81 3.56 J 2 mg/L Ref. 24, pp. 183, 326; Ref. 28, p. 73 

Methyl acetate T0126-00-81 97.7 J 2 mg/L Ref. 24, pp. 183, 326; Ref. 28, p. 73 

2-Butanone T0126-00-81 41,000 J 1,250 mg/L Ref. 24, pp. 183, 326; Ref. 28, p. 73 

Chloroform T0126-00-81 95.2 J 2 mg/L Ref. 24, pp. 183, 326; Ref. 28, p. 73 

4-Methyl-2-pentanone T0126-00-81 115 5 mg/L Ref. 24, pp. 184, 326; Ref. 28, p. 73 

Toluene T0126-00-81 2.51 J 2 mg/L Ref. 24, pp. 184, 326; Ref. 28, p. 73 

Ethylbenzene T0126-00-81 3.6 J 2 mg/L Ref. 24, pp. 184, 326; Ref. 28, p. 73 

meta-/para-Xylene T0126-00-81 13.1 J 4 mg/L Ref. 24, pp. 184, 326; Ref. 28, p. 73 

ortho-Xylene T0126-00-81 5.81 J 2 mg/L Ref. 24, pp. 184, 326; Ref. 28, p. 73 

Benzyl alcohol T0126-00-81 47.1 5 mg/L Ref. 24, pp. 185, 326; Ref. 28, p. 73 

Butyl benzyl phthalate T0126-00-81 12.8 5 mg/L Ref. 24, pp. 185, 326; Ref. 28, p. 73 

Naphthalene T0126-00-81 3.14 2 mg/L Ref. 24, pp. 186, 326; Ref. 28, p. 73 

Phenol T0126-00-81 20.1 J 5 mg/L Ref. 24, pp. 187, 326; Ref. 28, p. 73 

Chromium T0126-00-81 3.26 0.0806 mg/L Ref. 24, pp. 188, 326; Ref. 28, p. 73 

Zinc T0126-00-81 0.192 0.161 mg/L Ref. 24, pp. 188, 326; Ref. 28, p. 73 

Benzaldehyde T0212-00-81 0.787 BJ 0.755 mg/kg Ref. 24, pp. 191, 326; Ref. 28, p. 73 

Phenol T0212-00-81 0.864 BJ 0.755 mg/kg Ref. 24, pp. 193, 326; Ref. 28, p. 73 
Source Characterization - Source 5

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Hazardous

Substance

Evidence

References Sample ID Concentration Reporting 

Limit

Units 1

Methyl acetate T0212-00-81 4.78 0.25 mg/kg Ref. 24, pp. 189, 326; Ref. 28, p. 73 

Chromium T0212-00-81 88.1 13.2 mg/kg Ref. 24, pp. 194, 326; Ref. 28, p. 73 

Manganese T0212-00-81 551 K 6.6 mg/kg Ref. 24, pp. 194, 326; Ref. 28, p. 73 

Nickel T0212-00-81 205 26.3 mg/kg Ref. 24, pp. 194, 326; Ref. 28, p. 73 

Vanadium T0212-00-81 32.7 26.3 mg/kg Ref. 24, pp. 194, 326; Ref. 28, p. 73 

Zinc T0212-00-81 32.7 26.3 mg/kg Ref. 24, pp. 194, 326; Ref. 28, p. 73 

Notes:

(mg/L) milligrams per liter = 1,000 micrograms per liter (ug/L)

(mg/kg) milligrams per kilogram = 1,000 micrograms per kilogram (ug/kg)

J Identification of analyte is acceptable; the reported value is an estimate (Ref. 24, p. 328).

B Blank related – the concentration found in the sample was less than 10X the concentration found in the associated extraction, 

digestion and/or analysis blank.(Ref. 24, p. 328).

K The identification of the analyte is acceptable; the reported value may be biased high (for data analyzed by the EPA Region 6 

Environmental Services Branch Laboratory) (Ref. 24, p. 328).

1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory is a detection limit which has been adjusted for sample 

aliquot, sample volume, and dilutions for the analysis and meets the HRS definition of SQL (Ref. 1, Section 1.1; Ref. 24, p. 4; Ref. 

26).

2.4.2 Hazardous Waste Quantity

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1 Tier A: Hazardous Constituent Quantity - Not Evaluated (NE)

The information available is not sufficient to determine with reasonable confidence a hazardous 

constituent quantity for Source 5 (Ref. 1, Section 2.4.2.1.1). Scoring proceeds to the evaluation of Tier 

B, hazardous wastestream quantity (Ref. 1, Section 2.4.2.1.2).

2.4.2.1.2 Tier B: Hazardous Wastestream Quantity 

As part of the EPA emergency response activities, 212 400-gallon totes were found within the 

warehouse of the centralized waste treatment property at 400 N. Richey. Of these, 20 totes contain 

corrosive, and 62 totes contain flammable hazardous waste (Ref. 7, p. 19; Ref. 8, p. 8; Ref. 10, pp. 73-

86; Ref. 43, pp. 6-10). The remaining 130 totes stored at the facility were not included in the source 

hazardous wastestream quantity calculation since HAZCAT results did not identify their contents as 

RCRA hazardous waste exhibiting the characteristics indentified under Section 3001 of RCRA as 

amended (Ref. 1, Section 2.4.2.1.2; Ref. 10, pp. 73-86). The volume of each tote was estimated during 

container inventory and HAZCAT activities conducted during the July 2010 EPA Emergency 

Response as presented below (Ref. 7, p. 19, Ref. 10, pp. 73-86). During EPA response activities in 

July 2010, the totes were separated into waste streams that contained similar chemical traits using 

HAZCAT techniques (Ref. 7, p. 19). The following table presents a summary of the waste streams 

identified and their quantities (Ref. 10 pp. 73-86). 
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Waste Stream Matrix Volume

(Approx. Gal) Reference

Corrosive Acid Liquid 1460 Ref. 10, pp. 79, 80, 82, 84, 85

Corrosive Base Liquid 2010 Ref. 10, pp. 73, 76, 79, 81, 85

Flammable Liquid 19070 Ref. 10, pp. 73, 75-86

Flammable, Corrosive Acid Liquid 20 Ref. 10, p. 86

Flammable, Corrosive Base Liquid 800 Ref. 10, pp. 73, 75, 84

Subtotal Volume of Liquids 23,360

Corrosive Acid Gel 8 Ref. 10, p. 84

Flammable Gel 440 Ref. 10, pp. 74, 84

Subtotal Volume of Gel 448

Flammable, Corrosive Acid Liquid/Solid 40 Ref. 10, p. 86

Subtotal Volume of Liquid/Solids 40

Corrosive Acid Solid 120 Ref. 10, p. 84

Flammable Solid 140 Ref. 10, pp. 80, 86

Subtotal Volume of Solids 260

Total Volume 24,108

The total volume of the totes (liquids and solids) was calculated based on the container size (400 

gallons) and the content level of each tote determined during inventory (Ref. 10, pp. 73-86). The total 

volume of the totes containing hazardous substances equals 24,108 gallons. The Tier B equation for 

assigning a value for Hazardous Waste stream Quantity (W) is W (in pounds)/5,000 (Ref. 1, Table 2-

5).

Volume of source (gallons): 24,108

1 gallon = 10 pounds (Ref. 1, Table 2-5)

24,108 gallons = 241,080 pounds (lbs)

Hazardous Waste stream Quantity = 241,080 lbs/5,000

Hazardous Waste stream Quantity = 48.216

2.4.2.1.3 Tier C: Volume - Not Evaluated (NE)

Tier B, the hazardous waste stream quantity of the source has been estimated with reasonable 

confidence, therefore the value assigned for Tier C is not evaluated (Ref. 1, Section 2.4.2.1.4). 

Volume Assigned Value = Not Evaluated
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2.4.2.1.4 Tier D: Area - Not Evaluated (NE)

Tier B, the hazardous waste stream quantity of the source has been estimated with reasonable 

confidence, therefore the value assigned for Tier D is not evaluated (Ref. 1, Section 2.4.2.1.4).

Area Assigned Value = Not Evaluated

2.4.2.1.5

Tier Evaluated

Source Hazardous Waste Quantity Value

Per the HRS, the highest of the values assigned to the source for hazardous constituent quantity (Tier 

A), hazardous wastestream quantity (Tier B), volume (Tier C), and area (Tier D) should be assigned as 

the source hazardous waste quantity value (Ref. 1, Section 2.4.2.1.5).

Source 5 Values

A Not Evaluated

B 48.216

C Not Evaluated

D Not Evaluated

Source Hazardous Waste Quantity Value: 48.216
Source Characterization - Source 6

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SOURCE DESCRIPTION

2.2 Source Characterization

Source Description: Source 6 – Aboveground Tanks

The tank farm located at the northwest corner of the USOR property consists of 24 aboveground 

storage tanks (ASTs). Twenty of the ASTs have a tank capacity of approximately 16,000 to 17,000 

gallons, and four of the larger ASTs have a tank capacity of approximately 22,000 gallons. The 

majority of the tanks are full of a mixture of water, oily waste and sludge (Ref. 5, pp. 14, 66). These 

tanks have a combined storage capacity of approximately 440,000 gallons (Ref. 9, p. 2). These tanks 

are utilized to store hazardous waste; however, USOR is not authorized to store hazardous waste in 

these tanks or process hazardous waste (Ref. 9, p. 11).

During a 10 January 2006 TCEQ investigation, an unauthorized discharge was observed behind the 

tank farm where a black oily liquid had contaminated the ground. The impacted soil covered less than 

10 square feet. Based on correspondences received from USOR on 2 March 2006, the spill was a 

result of a break in a pipe that discharged approximately 50 to 100 gallons of oily water that sprayed 

over the containment wall (Ref. 5, p. 486).

On 1 June 2006, a TCEQ investigator found fractures in the tank farm’s concrete secondary 

containment wall that showed seepage of oily liquid. The TCEQ investigator also observed oily waste 

migrating outside the secondary containment (Ref. 5, pp. 16, 495, 496). Several of the tanks were 

visibly leaking during emergency response activities conducted during July 2010 and November to 

December 2010 (Ref. 43, pp 3, 7, 23-25). As a result of several tanks leaking in the north tank farm, 

oily liquids and sludge from the tanks were drained into the containment area. Oily liquids and sludge 

from the tanks contained high levels of hydrogen sulfide and were neutralized for disposal as nonhazardous waste. A tank used to store acid was removed from the secondary containment area since 

the tank was leaking and had damaged the containment area berm. Concrete was poured into the acid 

containment area to repair the damaged berm (Ref. 5, pp. 20, 83).

Source Type

The waste contents are in aboveground storage tanks and, as such, the source type for Source 6 is 

“Tanks and Containers Other Than Drums” (Ref. 1, Table 2-5).

Source Location

The aboveground tanks are located at the USOR property located on the northwestern side of 400 N. 

Richey Street (Attachment A Figure A-2A; Ref. 14, p. 1).

During an EPA Compliance Evaluation Inspection in November 2009, it was noted that the vents for 

Source Containment

Release To Surface Water
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all of the tanks located in the tank storage area (north end of warehouse) were open to the atmosphere. 

Ambient VOC readings reached 306 parts per million (ppm). There were no gauges on the tanks. All 

of the tanks were filled to capacity. It was noted that operators stop filling the tanks once they begin to 

overflow. Oil was present in the tank containment area (Ref. 9, p. 8). During EPA emergency 

response activities in November 2010, hydrogen sulfide was found at significant levels in the north 

tank farm during recovery operations (Ref. 7, p. 26).

During one large rainfall event in July 2010, EPA found that several secondary containment areas 

around the ASTs were overflowing and the contents were flowing off-site (Ref. 5, p. 19, 90-92). 

During that same rain event, TCEQ found secondary containment areas located in the tank farm were 

overflowing oily liquids into the parking lot area, which was then discharging down the property’s

front driveway and into Vince Bayou (Ref. 5, pp. 19, 88, 89). In November 2010, the available 

freeboard in the secondary containment areas had become compromised due to heavy rains and the 

contents were overflowing to the parking lot (Ref. 6, pp. 105, 226-231; Ref. 7, p. 22). On 1 June 2006, 

a TCEQ investigator found fractures in the tank farm’s concrete secondary containment wall that 

showed seepage of oily liquid (Ref. 5, pp. 16, 495, 496).

Contents of the ASTs were exposed to precipitation and surface water (through flooding) (Ref. 6, pp. 

97, 142, 187). Several of the tanks were visibly leaking during emergency response activities 

conducted during July 2010 and November to December 2010 (Ref. 43, pp 3, 7, 23-25). As a result of 

several tanks leaking in the north tank farm, oily liquids and sludge from the tanks were drained into 

the containment area. Oily liquids and sludge from the tanks contained high levels of hydrogen sulfide 

and were neutralized to dispose of as non-hazardous waste. A tank used to store acid was removed 

from the secondary containment area since the tank was leaking and had damaged the containment 

area berm. Concrete was poured into the acid containment area to repair the damaged berm (Ref. 5, 

pp. 20, 83).

A containment value of 10 was selected for Source 6, Tanks and Containers Other Than Drums, based 

on evidence of hazardous substance migration from the containers into the secondary containment area 

around the drums and diking surrounding the container storage area was observed to be unsound (Ref. 

1, Table 4-2). 

Containment Value: 10

2.4.1 Hazardous Substances

On 15 and 16 November 2010, as part of EPA’s emergency response activities, EPA START-3 

collected two sludge samples from within the containment areas of the ASTs. One composite sample 

was collected from the North Tank Farm secondary containment (WP01) , one composite sample was 

collected from the South Tank Farm secondary containment (WP02) (Ref. 28, pp. 18, 22). The 

samples were hand delivered to Accutest Laboratories located in Houston, Texas. The samples were 

analyzed for Toxicity Characteristic Leaching Procedure (TCLP) VOCs by SW846 1311/8260B, 

TCLP SVOCs by SW846 1311/8270C, and Resource Conservation and Recovery Act (RCRA) list 

total and TCLP metals with mercury by SW846 1311/6010B/7470A (Ref. 45, p. 24).

As part of supplemental sampling of the USOR site, EPA START-3 collected waste samples from two 

ASTs located on the north tank farm of 400 N. Richey Street (NTF-01-00-81 and NTF-02-00-81) (Ref.
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28, p. 73; Ref. 44, p. 4). The samples were analyzed for VOCs and SVOCs by CLP OLM04.2 and for 

TAL metals and mercury by CLP ISM05.3 by the EPA Region 6 Environmental Services Branch 

Laboratory (Ref. 24, pp. 195-206, 327; Ref. 28, p. 73; Ref. 45, pp. 8-17, 24). 

Analytical evidence of the contamination in waste source samples associated with the ASTs and their 

associated secondary containments located on the USOR site is summarized in the following table. 

Hazardous

Substance

Evidence

Sample References ID Concentration MQL/RL Units 1

EPA Emergency Response Activities – November 2010

Benzene

2

WP01-71-101115 3.75 0.25 3 mg/L Ref. 45, pp. 8, 24; Ref.49, pp. 1,6

Methyl ethyl ketone WP01-71-101115 0.695 0.50 3 mg/L Ref. 45, pp. 8, 24; Ref.49, pp. 1,6

2-Methylphenol WP01-71-101115 0.0878 0.050 3 mg/L Ref. 45, pp. 9, 24;Ref.49, pp. 9,14

3&4-Methylphenol WP01-71-101115 0.471 0.050 3 mg/L Ref. 45, pp. 9, 24; Ref.49, pp. 9, 14

Arsenic WP01-71-101115 0.027 B 0.050 3 mg/L Ref. 45, pp. 10, 24; Ref.49, p. 17

Barium WP01-71-101115 0.42 B 5.0 3 mg/L Ref. 45, pp. 10, 24; Ref.49, p. 17

Lead WP01-71-101115 0.011 B 0.025 3 mg/L Ref. 45, pp. 10, 24; Ref.49, p. 17

Arsenic WP01-71-101115 39.3 0.83 mg/kg Ref. 45, pp. 12, 24; Ref.49, pp. 17, 

22

Barium WP01-71-101115 1790 17 mg/kg Ref. 45, pp. 12, 24; Ref.49, pp. 17, 

22

Cadmium WP01-71-101115 1.2 0.41 mg/kg Ref. 45, pp. 12, 24; Ref.49, pp. 17, 

22

Chromium WP01-71-101115 78.7 0.83 mg/kg Ref. 45, pp. 12, 24; Ref.49, pp. 17,

22

Lead WP01-71-101115 133 0.83 mg/kg Ref. 45, pp. 12, 24; Ref.49, pp. 17, 

22

Mercury WP01-71-101115 15.3 1.2 mg/kg Ref. 45, pp. 12, 24; Ref.49, pp. 17, 

22

Silver WP01-71-101115 1.5 0.83 mg/kg Ref. 45, pp. 12, 24; Ref.49, pp. 17, 

22

Benzene WP02-71-101116 0.0322 0.25 3 mg/L Ref. 45, pp. 13, 24; Ref.49, pp. 1,7

Methyl ethyl ketone WP02-71-101116 0.702 0.50 3 mg/L Ref. 45, pp. 13, 24; Ref.49, pp. 1,7

2-Methylphenol WP02-71-101116 0.0384 0.050 3 mg/L Ref. 45, pp. 14, 24; Ref.49, pp. 9, 15

3&4-Methylphenol WP02-71-101116 0.232 0.050 3 mg/L Ref. 45, pp. 14, 24; Ref.49, pp. 9, 15

Arsenic WP02-71-101116 0.023 B 0.050 3 mg/L Ref. 45, pp. 15, 24; Ref.49, p. 17

Barium WP02-71-101116 0.15 B 5.0 3 mg/L Ref. 45, pp. 15, 24; Ref.49, p. 17

Chromium WP02-71-101116 0.015 B 0.050 3 mg/L Ref. 45, pp. 15, 24; Ref.49, p. 17

Lead WP02-71-101116 0.012 B 0.025 3 mg/L Ref. 45, pp. 15, 24; Ref.49, p. 17

Mercury WP02-71-101116 0.0096 0.0020 3 mg/L Ref. 45, pp. 15, 24; Ref.49, p. 17

Selenium WP02-71-101116 0.029 B 0.25 3 mg/L Ref. 45, pp. 15, 24; Ref.49, p. 17
Source Characterization - Source 6

HRS Documentation Record 51 US Oil Recovery

TXN000607093

Hazardous

Substance

Evidence

Sample References ID Concentration MQL/RL Units 1

Arsenic WP02-71-101116 13.7 1.4 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 

23

Barium WP02-71-101116 1720 28 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 

23

Cadmium WP02-71-101116 1.6 0.69 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 

23

Chromium WP02-71-101116 101 1.4 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 

23

Lead WP02-71-101116 96.6 1.4 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 

23

Mercury WP02-71-101116 45.1 2.1 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 

23

Selenium WP02-71-101116 0.46 B 1.4 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 

23

Silver WP02-71-101116 1.5 1.4 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 

23

EPA Supplemental Sampling Activities – March 2011

Acetone NFT-01-00-81 70.5 10 mg/L Ref. 24, pp. 195, 327; Ref. 28, p. 73

Methyl tert-butyl ether NFT-01-00-81 2.38 0.2 mg/L Ref. 24, pp. 195, 327; Ref. 28, p. 73

2-Butanone NFT-01-00-81 90.2 5.0 mg/L Ref. 24, pp. 195, 327; Ref. 28, p. 73

Cyclohexane NFT-01-00-81 0.670 0.2 mg/L Ref. 24, pp. 195, 327; Ref. 28, p. 73

Benzene NFT-01-00-81 9.65 0.2 mg/L Ref. 24, pp. 195, 327; Ref. 28, p. 73

Methylcyclohexane NFT-01-00-81 0.555 0.2 mg/L Ref. 24, pp. 195, 327; Ref. 28, p. 73

4-methyl-2-pentanone NFT-01-00-81 2.4 0.5 mg/L Ref. 24, pp. 196, 327; Ref. 28, p. 73

Toluene NFT-01-00-81 14.0 0.2 mg/L Ref. 24, pp. 196, 327; Ref. 28, p. 73

Ethylbenzene NFT-01-00-81 10.4 0.2 mg/L Ref. 24, pp. 196, 327; Ref. 28, p. 73

meta-/para-Xylene NFT-01-00-81 32.4 4.0 mg/L Ref. 24, pp. 196, 327; Ref. 28, p. 73

ortho-Xylene NFT-01-00-81 14.8 0.2 mg/L Ref. 24, pp. 196, 327; Ref. 28, p. 73

Styrene NFT-01-00-81 1.01 0.2 mg/L Ref. 24, pp. 196, 327; Ref. 28, p. 73

Isopropylbenzene NFT-01-00-81 0.65 0.2 mg/L Ref. 24, pp. 196, 327; Ref. 28, p. 73

Acenapthene NFT-01-00-81 0.342 0.30 mg/L Ref. 24, pp. 197, 327; Ref. 28, p. 73

Benzoic acid NFT-01-00-81 29.8 J 27.0 mg/L Ref. 24, pp. 197, 327; Ref. 28, p. 73

1,1’-Biphenyl NFT-01-00-81 3.06 0.75 mg/L Ref. 24, pp. 197, 327; Ref. 28, p. 73

2,4-Dimethylphenol NFT-01-00-81 0.86 0.75 mg/L Ref. 24, pp. 198, 327; Ref. 28, p. 73

Fluorene NFT-01-00-81 0.489 0.30 mg/L Ref. 24, pp. 198, 327; Ref. 28, p. 73

2-Methylnaphthalene NFT-01-00-81 8.46 0.30 mg/L Ref. 24, pp. 198, 327; Ref. 28, p. 73

2-Methylphenol NFT-01-00-81 2.37 0.75 mg/L Ref. 24, pp. 198, 327; Ref. 28, p. 73

3&/or4-Methylphenol NFT-01-00-81 4.73 0.75 mg/L Ref. 24, pp. 198, 327; Ref. 28, p. 73

Napthalene NFT-01-00-81 40.9 6.0 mg/L Ref. 24, pp. 198, 327; Ref. 28, p. 73

Phenanthrene NFT-01-00-81 0.944 0.3 mg/L Ref. 24, pp. 199, 327; Ref. 28, p. 73
Source Characterization - Source 6

HRS Documentation Record 52 US Oil Recovery

TXN000607093

Hazardous

Substance

Evidence

Sample References ID Concentration MQL/RL Units 1

Phenol NFT-01-00-81 17.8 1.5 mg/L Ref. 24, pp. 199, 327; Ref. 28, p. 73

Pyrene NFT-01-00-81 0.50 0.3 mg/L Ref. 24, pp. 199, 327; Ref. 28, p. 73

Barium NFT-01-00-81 5.12 0.1 mg/L Ref. 24, pp. 200, 327; Ref. 28, p. 73

Chromium NFT-01-00-81 1.07 0.1 mg/L Ref. 24, pp. 200, 327; Ref. 28, p. 73

Cobalt NFT-01-00-81 0.367 0.2 mg/L Ref. 24, pp. 200, 327; Ref. 28, p. 73

Copper NFT-01-00-81 7.37 0.2 mg/L Ref. 24, pp. 200, 327; Ref. 28, p. 73

Lead NFT-01-00-81 1.48 0.3 mg/L Ref. 24, pp. 200, 327; Ref. 28, p. 73

Manganese NFT-01-00-81 14.3 0.05 mg/L Ref. 24, pp. 200, 327; Ref. 28, p. 73

Nickel NFT-01-00-81 2.65 0.2 mg/L Ref. 24, pp. 200, 327; Ref. 28, p. 73

Vanadium NFT-01-00-81 0.966 0.2 mg/L Ref. 24, pp. 200, 327; Ref. 28, p. 73

Zinc NFT-01-00-81 39.7 0.2 mg/L Ref. 24, pp. 200, 327; Ref. 28, p. 73

Acetone NTF-02-00-81 11.7 2.48 mg/kg Ref. 24, pp. 201, 327; Ref. 28, p. 73

Methyl tert-butyl ether NTF-02-00-81 2.24 0.0993 mg/kg Ref. 24, pp. 201, 327; Ref. 28, p. 73

2-Butanone NTF-02-00-81 17.3 1.24 mg/kg Ref. 24, pp. 201, 327; Ref. 28, p. 73

Cyclohexane NTF-02-00-81 4.17 0.496 mg/kg Ref. 24, pp. 201, 327; Ref. 28, p. 73

Benzene NTF-02-00-81 69.1 9.93 mg/kg Ref. 24, pp. 201, 327; Ref. 28, p. 73

Trichloroethene NTF-02-00-81 0.679 0.0993 mg/kg Ref. 24, pp. 201, 327; Ref. 28, p. 73

Methylcyclohexane NTF-02-00-81 6.32 0.496 mg/kg Ref. 24, pp. 201, 327; Ref. 28, p. 73

4-Methyl-2-pentanone NTF-02-00-81 3.92 1.24 mg/kg Ref. 24, pp. 202, 327; Ref. 28, p. 73

Toluene NTF-02-00-81 153 9.93 mg/kg Ref. 24, pp. 202, 327; Ref. 28, p. 73

Tretrachloroethene NTF-02-00-81 2.21 J 0.0993 mg/kg Ref. 24, pp. 202, 327; Ref. 28, p. 73

Ethylbenzene NTF-02-00-81 117 9.93 mg/kg Ref. 24, pp. 202, 327; Ref. 28, p. 73

meta-/para-Xylene NTF-02-00-81 455 19.9 mg/kg Ref. 24, pp. 202, 327; Ref. 28, p. 73

ortho-Xylene NTF-02-00-81 158 9.93 mg/kg Ref. 24, pp. 202, 327; Ref. 28, p. 73

Styrene NTF-02-00-81 12.5 0.496 mg/kg Ref. 24, pp. 202, 327; Ref. 28, p. 73

Isopropylbenzene NTF-02-00-81 9.24 0.496 mg/kg Ref. 24, pp. 202, 327; Ref. 28, p. 73

Acenapthene NTF-02-00-81 39.8 10.4 mg/kg Ref. 24, pp. 203, 327; Ref. 28, p. 73

Anthracene NTF-02-00-81 17.5 10.4 mg/kg Ref. 24, pp. 203, 327; Ref. 28, p. 73

Benzo(a)anthracene NTF-02-00-81 49.8 25.9 mg/kg Ref. 24, pp. 203, 327; Ref. 28, p. 73

Benzo(a)pyrene NTF-02-00-81 30.0 25.9 mg/kg Ref. 24, pp. 203, 327; Ref. 28, p. 73

1,1’-Biphenyl NTF-02-00-81 87.7 25.9 mg/kg Ref. 24, pp. 203, 327; Ref. 28, p. 73

Bis(2-

ethylhexyl)phthalate

NTF-02-00-81 39.4 25.9 mg/kg Ref. 24, pp. 203, 327; Ref. 28, p. 73

Chrysene NTF-02-00-81 78.2 25.9 mg/kg Ref. 24, pp. 204, 327; Ref. 28, p. 73

Fluoranthene NTF-02-00-81 13.3 10.4 mg/kg Ref. 24, pp. 204, 327; Ref. 28, p. 73

Fluorene NTF-02-00-81 48.9 10.4 mg/kg Ref. 24, pp. 204, 327; Ref. 28, p. 73

2-Methylnapthalene NTF-02-00-81 562 20.7 mg/kg Ref. 24, pp. 204, 327; Ref. 28, p. 73

Naphthalene NTF-02-00-81 1,700 207 mg/kg Ref. 24, pp. 204, 327; Ref. 28, p. 73
Source Characterization - Source 6

HRS Documentation Record 53 US Oil Recovery

TXN000607093

Hazardous

Substance

Evidence

Sample References ID Concentration MQL/RL Units 1

Phenanthrene NTF-02-00-81 149 10.4 mg/kg Ref. 24, pp. 205, 327; Ref. 28, p. 73

Phenol NTF-02-00-81 70.0 25.9 mg/kg Ref. 24, pp. 205, 327; Ref. 28, p. 73

Pyrene NTF-02-00-81 86.7 J 10.4 mg/kg Ref. 24, pp. 205, 327; Ref. 28, p. 73

Barium NTF-02-00-81 394 11.8 mg/kg Ref. 24, pp. 206, 327; Ref. 28, p. 73

Chromium NTF-02-00-81 61.7 11.8 mg/kg Ref. 24, pp. 206, 327; Ref. 28, p. 73

Copper NTF-02-00-81 345 23.6 mg/kg Ref. 24, pp. 206, 327; Ref. 28, p. 73

Lead NTF-02-00-81 86.4 35.4 mg/kg Ref. 24, pp. 206, 327; Ref. 28, p. 73

Manganese NTF-02-00-81 357 5.9 mg/kg Ref. 24, pp. 206, 327; Ref. 28, p. 73

Nickel NTF-02-00-81 114 23.6 mg/kg Ref. 24, pp. 206, 327; Ref. 28, p. 73

Vanadium NTF-02-00-81 134 23.6 mg/kg Ref. 24, pp. 206, 327; Ref. 28, p. 73

Zinc NTF-02-00-81 986 23.6 mg/kg Ref. 24, pp. 206, 327; Ref. 28, p. 73

Notes:

(mg/L) milligrams per liter = 1,000 micrograms per liter (ug/L)

(mg/kg) milligrams per kilogram = 1,000 micrograms per kilogram (ug/kg)

J Identification of analyte is acceptable; the reported value is an estimate (Ref. 24, p. 328).

B Indicates a result is greater than or equal to the Sample Detection Limit but less than the MQL (Ref. 45, pp. 10, 12, 15, 17, 20). 1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory and the Method Quantitation Limit (MQL) 

terminology is used by Accutest Laboratory. Both the RL and the MQL are detection limits which have been adjusted for sample 

aliquot, sample volume, and dilutions for the analysis and each meets the HRS definition of SQL (Ref. 1, Section 1.1; Ref. 24, p. 4; 

Ref. 26).

2 All laboratory data collected during EPA emergency response activities conducted November 2010 were validated by an EPA 

START-3 chemist in accordance with EPA Quality Assurance/Quality Control Guidance for Removal Activities, OSWER Directive 

9360.4-01 for definitive data use objectives and were found to be usable for the intended purpose. Data for target analytes meet the 

definitive data quality objective (Ref 49, pp. 5, 13, 21, 31). 3 These concentrations reported from the TCLP Leachate of the sample.
Source Characterization - Source 6

HRS Documentation Record 54 US Oil Recovery

TXN000607093

2.4.2 Hazardous Waste Quantity

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1 Tier A: Hazardous Constituent Quantity - Not Evaluated (NE)

The information available is not sufficient to determine with reasonable confidence a hazardous 

constituent quantity for Source 6 (Ref. 1, Section 2.4.2.1.1). Scoring proceeds to the evaluation of Tier 

B, hazardous wastestream quantity (Ref. 1, Section 2.4.2.1.2).

2.4.2.1.2 Tier B: Hazardous Wastestream Quantity - Not Evaluated (NE)

The information available is not sufficient to determine with reasonable confidence a hazardous 

wastestream quantity for Source 6 (Ref. 1, Sec. 2.4.2.1.2). Scoring proceeds to the evaluation of Tier 

C, volume (Ref. 1, Sec. 2.4.2.1.3).

2.4.2.1.3 Tier C: Volume

Two of the 17,000 gallon ASTs were sampled and found to contain hazardous substances through 

sampling (Ref. 24, pp. 195-206; Ref. 28, p. 73; Ref. 44, p. 4). These tanks were found to full and 

contained oily waste and sludge (Ref. 5, pp. 14, 66). The Tier C equation for assigning a value for 

volume of Tanks and Containers Other Than Drums is V/2.5 (Ref. 1, Table 2-5).

2 ASTs x 17,000 gallons each = 34,000 gallons

Volume of source (gallons): 34,000

34,000 gallons/201.97 (gallons per cubic yard) = 168.342 cubic yards

Volume Assigned Value = 168.342/2.5

Volume Assigned Value = 67.337

2.4.2.1.4 Tier D: Area - Not Evaluated (NE)

Tier C, volume, has already been determined; therefore, the value assigned for Tier D is not 

evaluated(Ref. 1, Section 2.4.2.1.4). 

Area Assigned Value = 0

Source Hazardous Waste Quantity Value

According to the HRS, the highest of the values assigned to the source for hazardous constituent 

quantity (Tier A), hazardous wastestream quantity (Tier B), volume (Tier C), and area (Tier D) should 

be assigned as the source hazardous waste quantity value (Ref. 1, Section 2.4.2.1.5).
Source Characterization - Source 6

HRS Documentation Record 55 US Oil Recovery

TXN000607093

Tier Evaluated Source 6 Values

A Not Evaluated

B Not Evaluated

C 67.337

D 0

Source Hazardous Waste Quantity Value: 67.337
Source Characterization - Source 7

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TXN000607093

SOURCE DESCRIPTION

2.2 Source Characterization

Source Description: Source 7 – Containment Pond

A containment pond is located on the west side of the warehouse at 400 N. Richey Street. During an 

inspection conducted by EPA on 14 December 2009, a waste delivery truck was observed discharging 

D001 hazardous waste (ignitable waste) from a discharge valve located in the back of the truck to the 

containment pond (Ref. 9, p. 9). Earlier in the same month, EPA inspectors also observed the 

containment pond overflowing and its contents flowing off-site. A sheen was present in the off-site 

discharge (Ref. 9, p. 16). 

Source Type

The waste contents are in a containment pond and as such, the source type for Source 7 is “Surface 

Impoundment” (Ref. 1, Table 2-5).

Source Location

The containment pond is located to the west of the warehouse located at 400 N. Richey Street (see 

Attachment A, Figure A-2A).

On 05 July 2010, EPA START-3 collected a containment pond sample (SWP) from the surface of the 

northeast corner of the pond for laboratory analysis (Ref. 27, pp. 17, 18). The sample was hand 

Source Containment

Release to Surface Water

During a 02 December 2009 EPA inspection, it was observed that the containment pond was 

overflowing and its contents flowing off-site. A sheen was present in the off-site discharge (Ref. 9, p. 

16). During a 02 July 2010 EPA ER, EPA observed an uncontrolled release of liquids from the 

containment pond (Ref. 7, p. 3; Ref. 27, p. 4). Contents of the containment pond are exposed to 

precipitation and surface water (through flooding) (Ref. 6, pp. 63, 70, 108, 124). Although the pond is 

lined, there is evidence of hazardous substance migration through direct observation and no diking 

/secondary containment around the pond present (Ref. 6, pp. 63, 70, 108, 124; Ref. 9, p. 16; Ref. 43, 

pp. 21, 22).

A containment value of 10 was selected for the Source 6 based on evidence of hazardous substance 

migration and lack of diking/secondary containment (Ref. 1, Table 4-2). 

Containment Value: 10

2.4.1 Hazardous Substances
Source Characterization - Source 7

HRS Documentation Record 57 US Oil Recovery

TXN000607093

delivered to Accutest Laboratories located in Houston, Texas. The sample was analyzed for VOCs by 

SW846 8260B, SVOC by SW846 8270C, and TAL metals with mercury by SW846 6010B/7470A 

(Ref. 27, p. 18; Ref. 32, pp. 7-12, 16, 17). Sample results for the containment pond indicate that the 

pond contained concentrations of acetone, phthalates and metals (Ref. 33, pp. 5, 15, 22).

Analytical evidence of the contamination in the source sample associated with Source 6, Surface 

Impoundment, located on the USOR site in the following table.

Hazardous

Substance

Evidence

References Sample ID No. Concentration

mg/L

MQL

EPA Emergency Response Activities – July 2010

1

mg/L

Acetone

2

SWP-05072010 0.0082 JQ 0.050 Ref. 32, p. 16; Ref. 33, pp. 

1,5

Di-n-butyl phthalate SWP-05072010 0.0011 JQ 0.005 Ref. 32, p. 16; Ref. 33, pp. 

1,15

Bis(2-Ethylhexyl)phthalate SWP-05072010 0.0041 JQ 0.005 Ref. 32, p. 16; Ref. 33, pp. 

1,15

Arsenic SWP-05072010 0.0123 0.0050 Ref. 32, p. 16; Ref. 33, pp. 

1,22

Barium SWP-05072010 0.0509 JQ 0.20 Ref. 32, p. 16; Ref. 33, pp. 

1,22

Manganese SWP-05072010 0.108 0.015 Ref. 32, p. 16; Ref. 33, pp. 

1,22

Nickel SWP-05072010 0.0428 0.040 Ref. 32, p. 16; Ref. 33, pp. 

1,22

Vanadium SWP-05072010 0.0018 JQ 0.050 Ref. 32, p. 16; Ref. 33, pp. 

1,22

Zinc SWP-05072010 0.0417 0.020 Ref. 32, p. 16; Ref. 33, pp. 

1,22

Notes:

mg/L) milligrams per liter = 1,000 micrograms per liter (ug/L)

J The value is an estimated quantity (Ref. 33, p. 2).

Q The reported concentration is less than the Method Quantitation Limit but greater than the Sample Detection Limit (Ref. 33, p. 2). 1 The Laboratory used Method Quantitation Limit (MQL) terminology in place of RL or SQL. MQL is defined as the sample detection 

limit adjusted for sample aliquot, sample volume, and dilutions for the analysis (Ref. 26).

2 All laboratory data collected during EPA emergency response activities July 2010 were validated by a START chemist in accordance 

with EPA Quality Assurance/Quality Control Guidance for Removal Activities, OSWER Directive 9360.4-01 for definitive data use 

objectives and were found to be usable for the intended purpose. All data for target analytes meet the definitive data quality objective 

(Ref. 33, pp. 4, 13, 21).
Source Characterization - Source 7

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TXN000607093

2.4.2 Hazardous Waste Quantity

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1 Tier A: Hazardous Constituent Quantity - Not Evaluated (NE)

The information available is not sufficient to determine with reasonable confidence a hazardous 

constituent quantity for Source 7 (Ref. 1, Section 2.4.2.1.1). Scoring proceeds to the evaluation of Tier 

B, hazardous wastestream quantity (Ref. 1, Section 2.4.2.1.2).

2.4.2.1.2 Tier B: Hazardous Wastestream Quantity - Not Evaluated (NE)

The information available is not sufficient determine with reasonable confidence a hazardous 

wastestream quantity for Source 7 (Ref. 1, Sec. 2.4.2.1.2). Scoring proceeds to the evaluation of Tier 

C, volume (Ref. 1, Sec. 2.4.2.1.3).

2.4.2.1.3 Tier C: Volume

The containment pond measures 240 feet long by 85 feet wide and 6 feet deep (Ref. 25, pp. 1, 2). The 

Tier C equation for assigning a value for volume of a Surface Impoundment is V/2.5 (Ref. 1, Table 2-

5).

240 x 85 x 6 = 122,400 cubic feet

122,400 cubic feet /27 cubic feet per 1 cubic yard = 4,533.333 cubic yards

Volume of source (cubic yards): 4,533.333

Volume Assigned Value = 4,533.333/2.5

Volume Assigned Value = 1,813.333

2.4.2.1.4 Tier D: Area- Not Evaluated (NE)

Tier C, volume, has already been determined; therefore, the value assigned for Tier D is not evaluated 

(Ref. 1, Section 2.4.2.1.4). 

Area Assigned Value = 0

Source Hazardous Waste Quantity Value

According to the HRS, the highest of the values assigned to the source for hazardous constituent 

quantity (Tier A), hazardous wastestream quantity (Tier B), volume (Tier C), and area (Tier D) should 

be assigned as the source hazardous waste quantity value (Ref. 1, Section 2.4.2.1.5).
Source Characterization - Source 7

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Tier Evaluated Source 4 Values

A Not Evaluated

B Not Evaluated

C 1,813.333

D 0

Source Hazardous Waste Quantity Value: 1,813.333
Source Characterization - Source 8

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SOURCE DESCRIPTION

2.2 Source Characterization

Source Description: Source 8 – Roll-Off Boxes

Source 8 is being evaluated, but is not being used in scoring. It is included to show other waste 

identified at the Site. 

Two hundred twenty-five 20 to 25-cubic yard roll-off boxes are located throughout the property at 400 

N. Richey Street. Most of these roll-off boxes were labeled “Hazardous Waste October 2009” or 

“Hazardous Waste December 2009” (Ref. 5, pp, 14, 75). Many of these roll-off boxes were open to 

the elements and issues with these containers included leaks, tarps with holes, missing tarps, missing 

or damaged pipes, and missing or damaged bows; all of which can result in an overflow of material 

stored within them (Ref. 5, pp. 18-19, 62, 63, 288; Ref. 7, pp. 10-11; Ref. 43, pp. 4, 17-20). In July 

2010, as part of the EPA ER activities, these roll-off boxes were securely covered to prevent rainwater 

from entering them causing them to overflow and pose an imminent threat to human health and the 

environment (Ref. 7, p. 11).

On 25 September 2009, USOR received a letter from the US Coast Guard requiring them to remove 

the contents of the bioreactors on-site. The two bioreactors had incurred partial structural failure from 

a spill incident that had occurred 14 March 2009 (Ref. 9, p. 5). On 01 October 2009, USOR began 

removing the bioreactor’s contents and placing these contents into roll-off boxes and storing them onsite (Ref. 8, p. 3). 

During a December 2009 EPA inspection, a roll-off box containing hazardous waste from the 

bioreactor was observed to be leaking. It was raining and the rain was washing the hazardous waste 

into the stormwater that was draining off-site(Ref. 9, p. 9).

In July 2010, EPA initiated an ER and removal action at the USOR site. EPA found the site to be 

abandoned with no restriction to public access, and that releases of hazardous substances were 

occurring at the site. Numerous roll-off boxes (labeled as containing hazardous waste) were filled with 

liquid that was overflowing onto the ground and migrating off-site. The majority of the roll-off boxes 

were not properly secured and were open to weather conditions (Ref. 5, p. 19, 62). During the July 

2010 EPA Emergency Response, the content level of each of the roll-off boxes was measured and the 

total quantity of waste was calculated to be 2,833.25 cubic yards (Ref. 10, pp. 63-73).

Source Type

The waste is contained in roll-off boxes and, as such, the source type for Source 8 is “Tanks and 

Containers Other than Drums” (Ref. 1, Table 2-5; Ref. 7, pp. 10-11).

The roll-off boxes are on the property at 400 N. Richey Street and are staged on the parking lots north, 

Source Location
Source Characterization - Source 8

HRS Documentation Record 61 US Oil Recovery

TXN000607093

south, and east of the office/warehouse building (Ref. 8, pp. 4-5; Ref. 9, p. 6; Figure A-2A).

Hazardous

Substance

Source Containment

Release To Surface Water

During a December 2009 EPA Compliance Evaluation Inspection, roll-off boxes containing hazardous 

waste from the bioreactor were observed to be leaking. It was raining at the time of the inspection and 

the rain was washing the hazardous waste into the stormwater that was draining off-site (Ref. 9, pp. 9, 

13). Contents of the roll-off boxes were exposed to precipitation and surface water (through flooding). 

An inspection of the roll-off boxes, as described in an October through November 2009 TCEQ 

Investigation Report, revealed that waste had spilled or leaked from a number of the containers. 

Although a plastic liner and aggregate were placed over the ground by USOR prior to putting the rolloff boxes in place, sludge and liquid that was released posed an imminent threat of environmental 

contamination because no berm or other means of confinement were installed around the plastic liner 

to prevent run-on and run-off of stormwater from the site. The boxes did not have a proper 

containment system applicable to hazardous waste containers (Ref. 8, pp. 9, 91-97, 102-109, 151-162). 

During the July 2010 EPA ER, material from the roll-off boxes labeled as containing hazardous waste 

and having no tarp cover was observed actively flowing from the roll-off boxes off-site (Ref. 7, p. 3; 

Ref. 43, pp. 4, 17, 19, 20).

A containment value of 10 was selected for Source 8 based on evidence of hazardous substance 

migration from the containers and no diking/secondary containment (or no similar structure) 

surrounding the roll-off boxes (Ref. 8, pp. 9, 91-97, 102-109, 151-162; Ref. 1, Table 4-2). 

Containment Value: 10

2.4.1 Hazardous Substances

As part of supplemental sampling of the USOR site, EPA START-3 collected waste samples from one 

of the roll-off boxes (RO132) (Ref. 28, p. 73; Ref. 44, p. 4). The roll-off box was located on the 

parking lot of the USOR property at 400 N. Richey Street (Ref. 8, pp. 4-5; Ref. 9, p. 6 ). The sample 

was analyzed for VOCs and SVOCs by CLP OLM04.2 and for TAL metals and mercury by CLP 

ISM05.3 by the EPA Region 6 Environmental Services Branch Laboratory (Ref. 24, pp. 207-212, 327;

Ref. 28, p. 73;).

Analytical evidence of the contamination in waste source samples associated with the Roll-Off Boxes 

located on the USOR site is summarized in the following table. 

Evidence

References Sample ID Concentration

(mg/kg)

Reporting Limit

EPA Supplemental Sampling Activities – March 2011 

1

(mg/kg)

Acetone RO132-01-00-81 5.18 1.59 Ref. 24, pp. 207, 327; Ref. 28, p.73
Source Characterization - Source 8

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Hazardous

Substance

Evidence

References Sample ID Concentration

(mg/kg)

Reporting Limit

Methylene chloride

1

(mg/kg)

RO132-01-00-81 2.37 0.318 Ref. 24, pp. 207, 327; Ref. 28, p.73

2-Butanone RO132-01-00-81 6.69 0.795 Ref. 24, pp. 207, 327; Ref. 28, p.73

Cyclohexane RO132-01-00-81 1.95 0.318 Ref. 24, pp. 207, 327; Ref. 28, p.73

Benzene RO132-01-00-81 13.5 0.318 Ref. 24, pp. 207, 327; Ref. 28, p.73

Trichloroethene RO132-01-00-81 11.0 0.318 Ref. 24, pp. 207, 327; Ref. 28, p.73

Methylcyclohexane RO132-01-00-81 2.11 0.318 Ref. 24, pp. 207, 327; Ref. 28, p.73

4-Methyl-2-pentanone RO132-01-00-81 1.86 0.795 Ref. 24, pp. 208, 327; Ref. 28, p.73

Toluene RO132-01-00-81 43.4 1.59 Ref. 24, pp. 208, 327; Ref. 28, p.73

Tetrachloroethene RO132-01-00-81 3.42 0.318 Ref. 24, pp. 208, 327; Ref. 28, p.73

Ethylbenzene RO132-01-00-81 84.5 1.59 Ref. 24, pp. 208, 327; Ref. 28, p.73

meta/para-Xylene RO132-01-00-81 334 J 3.18 Ref. 24, pp. 208, 327; Ref. 28, p.73

ortho-Xylene RO132-01-00-81 124 1.59 Ref. 24, pp. 208, 327; Ref. 28, p.73

Styrene RO132-01-00-81 26.0 1.59 Ref. 24, pp. 208, 327; Ref. 28, p.73

Isopropylbenzene RO132-01-00-81 11.0 0.318 Ref. 24, pp. 208, 327; Ref. 28, p.73

Acenaphthene RO132-01-00-81 25.5 5.46 Ref. 24, pp. 209, 327; Ref. 28, p.73

Anthracene RO132-01-00-81 12.0 5.46 Ref. 24, pp. 209, 327; Ref. 28, p.73

Benzo(a)anthracene RO132-01-00-81 31.5 13.6 Ref. 24, pp. 209, 327; Ref. 28, p.73

1,1’-Biphenyl RO132-01-00-81 61.2 13.6 Ref. 24, pp. 209, 327; Ref. 28, p.73

Bis(2-ethylhexyl)phthalate RO132-01-00-81 63.1 13.6 Ref. 24, pp. 209, 327; Ref. 28, p.73

Butyl benzyl phthalate RO132-01-00-81 16.8 13.6 Ref. 24, pp. 209, 327; Ref. 28, p.73

Chrysene RO132-01-00-81 29.5 13.6 Ref. 24, pp. 210, 327; Ref. 28, p.73

Di-n-butyl phthalate RO132-01-00-81 75.9 13.6 Ref. 24, pp. 210, 327; Ref. 28, p.73

Fluoranthene RO132-01-00-81 17.5 5.46 Ref. 24, pp. 210, 327; Ref. 28, p.73

Fluorene RO132-01-00-81 69.8 5.46 Ref. 24, pp. 210, 327; Ref. 28, p.73

2-Methylnapthalene RO132-01-00-81 623 27.3 Ref. 24, pp. 210, 327; Ref. 28, p.73

Napthalene RO132-01-00-81 1,330 54.6 Ref. 24, pp. 210, 327; Ref. 28, p.73

Phenanthrene RO132-01-00-81 118 5.46 Ref. 24, pp. 211, 327; Ref. 28, p.73

Phenol RO132-01-00-81 59.5 B 13.6 Ref. 24, pp. 211, 327; Ref. 28, p.73

Pyrene RO132-01-00-81 6.28 5.46 Ref. 24, pp. 211, 327; Ref. 28, p.73

Barium RO132-01-00-81 353 32.9 Ref. 24, pp. 212, 327; Ref. 28, p.73

Chromium RO132-01-00-81 101 32.9 Ref. 24, pp. 212, 327; Ref. 28, p.73

Cobalt RO132-01-00-81 182 65.9 Ref. 24, pp. 212, 327; Ref. 28, p.73

Copper RO132-01-00-81 478 65.9 Ref. 24, pp. 212, 327; Ref. 28, p.73

Manganese RO132-01-00-81 160 16.5 Ref. 24, pp. 212, 327; Ref. 28, p.73

Nickel RO132-01-00-81 220 65.9 Ref. 24, pp. 212, 327; Ref. 28, p.73

Zinc RO132-01-00-81 1,290 65.9 Ref. 24, pp. 212, 327; Ref. 28, p.73

Notes:
Source Characterization - Source 8

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(mg/kg) milligrams per kilogram = 1,000 micrograms per kilogram (ug/kg)

B Blank related – the concentration found in the sample was less than 10X the concentration found in the associated extraction, 

digestion and/or analysis blank.(Ref. 24, p. 328). 1 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory is a detection limit which has been adjusted for sample 

aliquot, sample volume, and dilutions for the analysis and meets the HRS definition of SQL (Ref. 1, Section 1.1; Ref. 24, p. 4; Ref. 

26).

2.4.2 Hazardous Waste Quantity

2.4.2.1 Source Hazardous Waste Quantity

2.4.2.1.1 Tier A: Hazardous Constituent Quantity - Not Evaluated (NE)

The information available is not sufficient to determine with reasonable confidence a hazardous 

constituent quantity for Source 8 (Ref. 1, Section 2.4.2.1.1). Scoring proceeds to the evaluation of Tier 

B, hazardous wastestream quantity (Ref. 1, Section 2.4.2.1.2).

2.4.2.1.2 Tier B: Hazardous Wastestream Quantity - Not Evaluated (NE)

The information available is not sufficient to determine with reasonable confidence a hazardous 

wastestream quantity for Source 8 (Ref. 1, Sec. 2.4.2.1.2). Scoring proceeds to the evaluation of Tier 

C, volume (Ref. 1, Sec. 2.4.2.1.3).

2.4.2.1.3 Tier C: Volume

During the July 2010 EPA Emergency Response, the content level of each of the roll-off boxes was 

measured and the total quantity of waste from them was calculated to be 2,833.25 cubic yards. This 

quantity was calculated based on the size of each roll-off (25 cubic yards) multiplied by the percent 

content found within each container (Ref. 10, pp. 63-73). The Tier C equation for assigning a value 

for volume of Tanks and Containers Other Than Drums is V/2.5 (Ref. 1, Table 2-5.While the 

calculation is shown, an actual value will not be assigned since this source is not being used to score 

the site.

Volume of source (cubic yards): 2,833.25

Volume Assigned Value = 2,833.25/2.5

Volume Assigned Value = 1,133.3

2.4.2.1.4 Tier D: Area - Not Evaluated (NE)

Tier C, volume, has already been determined; therefore, the value assigned for Tier D is not evaluated 

(Ref. 1, Section 2.4.2.1.4). 

Area Assigned Value = 0
Source Characterization - Source 8

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Tier Evaluated

Source Hazardous Waste Quantity Value

No value was assigned for Source 8 since it is being presented only to show additional waste located 

on the site and is not being used for scoring

Source 8 Values

A Not Evaluated

B Not Evaluated

C 1,133.3

D 0

Source Hazardous Waste Quantity Value: 1,133.3
Source Characterization 

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SITE SUMMARY OF SOURCE DESCRIPTIONS

Source

No.

Source Hazardous 

Waste Quantity

Value

1

Containment

Ground Water Surface Water Gas Air Particulate

1 33.896 NE 9 NE NE

2 1,173.333 NE 10 NE NE

3 48.889 NE 10 NE NE

4 2,605.912 NE 10 NE NE

5 48.216 NE 9 NE NE

6 67.337 NE 10 NE NE

7 1,813.333 NE 10 NE NE

TOTAL 5,790.916

 NE = Not Evaluated

1 = In addition to these sources, another source (Source 8) is discussed in section 2.2 of this HRS documentation record.
Ground Water Pathway – Not Scored

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3.0 GROUND WATER MIGRATION PATHWAY SCORE - NOT SCORED

The ground water migration pathway will not be scored because it is not expected to contribute 

significantly to the site score. The site score already exceeds 28.50 based only on the evaluation of the 

surface water pathway.
SW Pathway – Overland/Flood Migration

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4.0 SURFACE WATER MIGRATION PATHWAY

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

4.1.1 General Considerations

4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood Component

The hazardous substance migration path includes both the overland and the in-water segment that 

hazardous substances would take as they migrate away from sources at the site (Ref. 1, Section 

4.1.1.1). Hazardous substance migration path overland and in-water segments for Sources 1 through 8

are described in the following text. The surface water pathway is presented on Figures A-3 and A-4.

Overland Segments

The topography of the USOR property is generally flat although there is a slight slope across most of 

the property to the north and east, towards the Vince Bayou (Ref. 5, p. 30). This slope increases to a 

moderate slope between the USOR property and the bayou (Ref. 3, p. 1). Stormwater from the 

majority of the USOR property drains to the northeast, north, and northwest into Vince Bayou. 

Stormwater that falls in the southern part of the USOR site flows south and east to either a bar ditch 

located along the west side of N. Richey Street or across N. Richey Street directly into Vince Bayou. 

The bar ditch conveys stormwater to Vince Bayou at the bridge where N. Richey Road crosses Vince 

Bayou (Ref. 3, p. 1; Ref. 5, pp. 30; Ref. 6, pp. 64, 65, 105, 112, 220, 221). During large rain events, 

the water from Vince Bayou covers N. Richey Street and part of the entrance drive to the USOR 

property (Ref. 6, pp. 66). During a large rain event, water from Vince Bayou was observed 

approximately 4 feet above the road at the intersection of N. Richey Street and the USOR property on 

2 July 2010 (Ref. 6, pp. 66). 

At the MCC property, surface water migrates to storm drains and Vince Bayou. The topographical 

across the west plant slopes to the east towards the bayou. The topographical slope towards most of 

the east plant runs west towards the bayou (Ref. 6, pp. 27, 788).

Source 1 – Drums (Flammable and Corrosive)

For Source 1, drainage flows out of the drums through open tops, corroded bottoms and/or sides, and 

due to lack of containment, through the doorways and cracks within the building walls and floor, and 

then outside of the warehouse to the east (Ref. 6, pp. 102, 208, 210-212). Drainage continues east 

through the parking lot and down the entrance drive into the site (which slopes to the east) and either 

continues across N. Richey Street into Vince Bayou from there (approximately 400 feet and 

downgradient from the source), or enters a bar ditch located along the west side of N. Richey Street 

that continues approximately 220 feet north and enters Vince Bayou at the bridge where N. Richey 

Street crosses Vince Bayou to the northeast of the site (Attachment A, Figure A-2A; Ref. 3, p. 1; Ref. 

6, pp. 64, 65, 112; Ref. 15, pp.1-2). Vince Bayou constitutes the beginning of the in-water segment for 

the surface water pathway.

Source 2 – Bioreactors

For Source 2, located on the northwest side of the 400 N. Richey Street property, overland flow is to 

the north approximately 380 feet to Vince Bayou (Attachment A, Figure A-2A; Ref. 3, p. 1; Ref. 5, p. 

30; Ref. 15, pp.1-2). Vince Bayou constitutes the beginning of the in-water segment for the surface 
SW Pathway – Overland/Flood Migration

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water pathway.

Source 3 –Truck Bays used as Sumps

For Source 3, drainage flows over the open tops and through the cracks of the truck bay sumps due 

their lack of freeboard and deteriorated conditions (Ref. 6, pp. 104, 106, 217, 218, 227, 229). Source 3 

is located on the north side of the 400 N. Richey Street property and overland flow is downgradient to 

either the north approximately 250 feet or northeast approximately 200 feet to Vince Bayou 

(Attachment A, Figure A-2A; Ref. 3, p. 1; Ref. 5, p. 30; Ref. 15, pp.1-2). Vince Bayou constitutes the 

beginning of the in-water segment for the surface water pathway.

Source 4 – MCC Surface impoundments

For Source 2, drainage flows over the open tops of the surface impoundments due to lack of 

containment features and continues to flow downgradient (Ref. 6, pp. 71-76, 82-84, 128, 130, 133, 

134, 145-149). From the Primary Clarifier, Aeration Basin (Final Clarifier), Lift Station 3, and 

Headworks (also known as oil water separator) located on the 200 N. Richey Street property (west side 

of Vince Bayou), the overland flow is to the northeast and flows approximately 50 feet to Vince 

Bayou. From the Digesters, Clarifiers, Chorine Contact Tank, Gravity Thickener and Lift Station 1 

located on the 200 N. Richey Street property (east side of Vince Bayou), the overland flow is to the 

west and flows approximately 120 feet to Vince Bayou (Attachment A, Figure A-2B; Ref. 3, p. 1; Ref. 

15, pp.1-2). Vince Bayou constitutes the beginning of the in-water segment for the surface water 

pathway.

Source 5 – Poly Totes (Flammable and Corrosive)

For Source 5, drainage flows out of the totes through opened bottoms and/or sides, and due to lack of 

containment, through the doorways and cracks within the building walls and floor and then outside of 

the warehouse to the east. Drainage continues east through the parking lot and down the entrance 

drive into the site (which slopes downgradient and to the east) and either continues across N. Richey 

Street into Vince Bayou (approximately 400 feet and downgradiant from the source), or enters a bar 

ditch located along the west side of N. Richey Street which continues approximately 220 feet north 

and enters Vince Bayou at the bridge where N. Richey Street crosses Vince Bayou to the northeast of 

the site (Attachment A, Figure A-2A; Ref. 3, p. 1; Ref. 6, pp. 64, 65, 112; Ref. 15, pp.1-2). Vince 

Bayou constitutes the beginning of the in-water segment for the surface water pathway.

Source 6 – Aboveground Storage Tanks

For Source 6, drainage flows from the leaking and open tanks, over the secondary containment which 

is inadequate to contain the liquids, and continues to flow downgradient to the north approximately 

250 feet to Vince Bayou (Attachment A, Figure A-2A; Ref. 3, p. 1; Ref. 5, p. 23; Ref. 15, pp.1-2). 

Vince Bayou constitutes the beginning of the in-water segment for the surface water pathway.

Source 7 – Containment Pond

For Source 7, drainage flows over the edges of the containment pond (due to lack of containment 

features) to the north approximately 380 feet to Vince Bayou (Attachment A, Figure A-2A; Ref. 3, p. 

1; Ref. 9, p. 16; Ref. 15, pp.1-2). Vince Bayou constitutes the beginning of the in-water segment for 

the surface water pathway.

Source 8 – Roll-Off Boxes

For Source 8, drainage occurs from four different paths from the roll-off boxes located throughout the 

site. For the roll-off boxes located to the east of the warehouse building, drainage continues east 
SW Pathway – Overland/Flood Migration

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through the parking lot and down the entrance drive into the site and continues across N. Richey Street 

into Vince Bayou (approximately 400 feet and downgradiant from the source), or enters a bar ditch 

located along the west side of N. Richey Street which continues approximately 220 feet north and 

enters Vince Bayou at the bridge where N. Richey Street crosses Vince Bayou to the northeast of the 

site. For the roll-off boxes located on the south side of the warehouse building, drainage is to the east 

approximately 150 feet to Vince Bayou. For the roll-off boxes located on the western side of the 

warehouse building, drainage is to the north approximately 380 feet to Vince Bayou (Attachment A, 

Figure A-2A; Ref. 3, p. 1; Ref. 6, pp. 64, 65, 112; Ref. 15, pp.1-2). Vince Bayou constitutes the 

beginning of the in-water segment for the surface water pathway.

In-Water Segments

The in-water segment begins at the Probable Point of Entry (PPE) to an eligible surface water body as 

defined in the HRS (Ref. 1, Sec. 4.1.1). Eligible surface water bodies that have been determined to be 

part of the in-water segment for the USOR site include Vince Bayou, Buffalo Bayou, the San Jacinto 

River, and several embayments which consist of Burnet Bay, Crystal Bay, Mitchell Bay, and Upper 

San Jacinto Bay (Attachment A, Figure A-4; Ref. 3, pp. 1-3). The aforementioned bays are tertiary 

bays to the Gulf of Mexico. Both Buffalo Bayou and the San Jacinto River are part of the Houston 

Ship Channel. All of the surface water bodies within the in-water segment are perennial and, 

therefore, eligible for HRS scoring (Ref. 1, Sec. 4.0.2; Ref. 3, pp. 1-3). The average annual rainfall at 

the US Oil Recovery site is approximately 54 inches (Ref. 16, p.1).

The target distance limit (TDL) for the surface water pathway, which defines the maximum distance 

over which targets are considered, is 15 miles. Although the eligible surface water bodies are tidally 

influenced, there are no significant upgradient targets; therefore, the tidal influence on the TDL was 

not evaluated (Ref. 1, Section 4.1.1.2; Ref. 51, p.1). The TDL is defined as being 15 miles from the 

farthest downstream PPE (i.e., PPE-06A) in the in-water segment section (Ref. 1, Sec. 4.1.1.2). The 

TDL of the surface water flow path is presented in Attachment A, Figure A-4 and is described in the 

following paragraphs.

Drainage from Sources 1 through 8 enters Vince Bayou at PPE-01 through PPE-06A (refer to 

Attachment A, Figure A-3). From PPE-1, the farthest downstream PPE, Vince Bayou flows for 

approximately 0.36 mile to its confluence with Buffalo Bayou (Houston Ship Channel). Buffalo 

Bayou (Houston Ship Channel) flows for approximately 10.3 miles before entering the San Jacinto 

River (Attachment A, Figure A-4; Ref. 3, pp. 1-3). The San Jacinto River within the in-water segment 

target distance limit has several embayments including Burnet Bay, Crystal Bay, Mitchell Bay, and 

Upper San Jacinto Bay (Attachment A, Figure A-4). Because of this, the surface water pathway within 

the San Jacinto River is measured as an arc rather than stream miles (Ref. 1, Sec. 4.1.1.1). Beginning 

at the confluence of Buffalo Bayou and the San Jacinto River, an arc with a radius of 4.34 miles was 

extended out to the terminus of the downgradient portion of the in-water segment (Attachment A, 

Figure A-4). 
SW Pathway – Likelihood of Release

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4.2 LIKELIHOOD OF RELEASE

4.2.1 Observed Release

Hazardous

Substance

Direct Observation

Direct observation has been established through materials seen entering the surface water by both 

migration and direct deposition. Additionally, evidence of sources flooding with material containing 

hazardous substances in direct contact with the surface water exists. Unpermitted discharges from the 

USOR site to Vince Bayou have been observed on several occasions by TCEQ, HCPHES and EPA 

personnel as presented in the following paragraphs (Ref. 6, pp. 18, 664-665; Ref. 9, p. 16; Ref. 12, pp. 

23-25; Ref. 18, pp. 2-11). 

In October 2009 and November 2009, HCPHES investigators observed discharges from the MCC 

Recycling property at 200 N. Richey Street into Vince Bayou. A ruptured 24-inch ribbed concrete 

pipe connected to the property was discovered discharging black effluent into Vince Bayou at a rate of 

approximately 200 gallons per minute (Ref. 18, pp. 3-6, 11). The pipe was found to be an abandoned

main influent line which was connected to the lift station at the MCC property (Ref. 18, pp. 4, 7, 8, 

27). On 23 and 27 October 2009, an HCPHES investigator collected samples labeled as Unknown, 

NA-26 from a black effluent which emitted a slight chemical odor and was observed flowing into 

Vince Bayou. These samples were located at Vince Bayou and West Richey Road, at the south side of 

the bridge and the east side of Vince Bayou (Ref. 18, pp. 3, 4, 7, 14, 20, 67; Ref. 54). Another sample 

was collected from the pipe at the line break (20126-01 24” Line Breaks) on 27 October 2009 (Ref. 18, 

pp. 7, 91, 97). Analytical results indicate that the discharged wastewater contained high 

concentrations of acetone, carbon disulfide, 2-butanone, 1,2-dichloroethane, benzene, 4-methyl-2-

pentanone, toluene, ethylbenzene, and xylenes, as well as benzoic acid, phenols, and naphthalenes

(Ref. 18, pp. 17-19, 72-73, 91-94). Analytical data from these discharges confirmed that the samples 

collected from the discharge point at Vince Bayou and the samples collected from the various tanks at 

the MCC property (East Digester, East Clarifier, West clarifier, West Digester, Lift Station) were 

substantially similar, and further confirmed that MCC was the source of the unauthorized discharges as 

shown in the table below (Ref. 18, pp. 10, 31-33, 39-41, 43, 47-49, 55-57, 63-65, 72-74, 79-81).

Evidence

Sample ID Concentration References 1 Units

HCPHES Investigation – October 2009

Discharge Samples

Acetone UNKNOWN, NA-26

(10/23/2009)

7.1 mg/L Ref. 18, pp. 17, 20

Carbon Disulfide UNKNOWN, NA-26

(10/23/2009)

0.057 mg/L Ref. 18, pp. 17, 20

2-Butanone UNKNOWN, NA-26

(10/23/2009)

0.78 mg/L Ref. 18, pp. 17, 20

1,2-Dichloroethane UNKNOWN, NA-26

(10/23/2009)

0.053 mg/L Ref. 18, pp. 17, 20
SW Pathway – Likelihood of Release

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Hazardous

Substance

Evidence

Sample ID Concentration References 1 Units

Benzene UNKNOWN, NA-26

(10/23/2009)

0.087 mg/L Ref. 18, pp. 17, 20

4-Methyl-2-pentanone 

(MIBK)

UNKNOWN, NA-26

(10/23/2009)

0.45 mg/L Ref. 18, pp. 17, 20

Toluene UNKNOWN, NA-26

(10/23/2009)

0.1 mg/L Ref. 18, pp. 17, 20

Ethylbenzene UNKNOWN, NA-26

(10/23/2009)

0.15 mg/L Ref. 18, pp. 17, 20

m/p Xylene UNKNOWN, NA-26

(10/23/2009)

0.63 mg/L Ref. 18, pp. 17, 20

o Xylene UNKNOWN, NA-26

(10/23/2009)

0.46 mg/L Ref. 18, pp. 18, 20

Acetone UNKNOWN, NA-26

(10/27/2009)

2.5 E mg/L Ref. 18, pp. 72, 76

Carbon Disulfide UNKNOWN, NA-26

(10/27/2009)

0.029 mg/L Ref. 18, pp. 72, 76

2-Butanone UNKNOWN, NA-26

(10/27/2009)

0.30 mg/L Ref. 18, pp. 72, 76

4-Methyl-2-pentanone 

(MIBK)

UNKNOWN, NA-26

(10/27/2009)

0.064 mg/L Ref. 18, pp. 72, 76

m/p Xylene UNKNOWN, NA-26

(10/27/2009)

0.090 mg/L Ref. 18, pp. 72, 76

o Xylene UNKNOWN, NA-26

(10/27/2009)

0.052D mg/L Ref. 18, pp. 73, 76

Acetone 20126-01 24” LINE 

BREAKS

6.99 mg/L Ref. 18, pp. 91, 97

Benzene 20126-01 24” LINE 

BREAKS

0.0245 mg/L Ref. 18, pp. 91, 97

Carbon disulfide 20126-01 24” LINE 

BREAKS 0.0299 mg/L Ref. 18, pp. 91, 97

1,2-Dichloroethane 20126-01 24” LINE 

BREAKS

0.0095 mg/L Ref. 18, pp. 91, 97

Ethylbenzene 20126-01 24” LINE 

BREAKS

0.0252 mg/L Ref. 18, pp. 91, 97

Methyl ethyl ketone 20126-01 24” LINE 

BREAKS

0.303 mg/L Ref. 18, pp. 91, 97

Tetrachloroethylene 20126-01 24” LINE 

BREAKS

0.0065 mg/L Ref. 18, pp. 91, 97

Toluene 20126-01 24” LINE 

BREAKS

0.0231 mg/L Ref. 18, pp. 91, 97

Trichloroethylene 20126-01 24” LINE 

BREAKS

0.0054 mg/L Ref. 18, pp. 91, 97

Xylene (total) 20126-01 24” LINE 

BREAKS

0.129 mg/L Ref. 18, pp. 92, 97

Benzoic Acid 20126-01 24” LINE 

BREAKS

1.03 mg/L Ref. 18, pp. 93, 97
SW Pathway – Likelihood of Release

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Hazardous

Substance

Evidence

Sample ID Concentration References 1 Units

2-Methylphenol 20126-01 24” LINE 

BREAKS

0.0864 mg/L Ref. 18, pp. 93, 97

3&4-Methylphenol 20126-01 24” LINE 

BREAKS

0.196 mg/L Ref. 18, pp. 93, 97

Phenol 20126-01 24” LINE 

BREAKS

0.692 mg/L Ref. 18, pp. 93, 97

Acenaphthene 20126-01 24” LINE 

BREAKS

0.0036 J ÷ 4.68

= 0.00076

mg/L Ref. 18, pp. 93, 97

Butyl benzyl phthalate 20126-01 24” LINE 

BREAKS

0.0037 J ÷ 10

= 0.00037

mg/L Ref. 18, pp. 93, 97

Chrysene 20126-01 24” LINE 

BREAKS

0.001 J ÷ 10

= 0.0001

mg/L Ref. 18, pp. 93, 97

Di-n-butyl phthalate 20126-01 24” LINE 

BREAKS

0.0032 J ÷ 10

= 0.00032

mg/L Ref. 18, pp. 94, 97

Bis(2-

Ethylhexyl)phthalate

20126-01 24” LINE 

BREAKS

0.0077 mg/L Ref. 18, pp. 94, 97

Fluorene 20126-01 24” LINE 

BREAKS

0.0026 J ÷ 10

= 0.00026

mg/L Ref. 18, pp. 94, 97

2-Methylnaphthalene 20126-01 24” LINE 

BREAKS

0.0319 mg/L Ref. 18, pp. 94, 97

Naphthalene 20126-01 24” LINE 

BREAKS

0.0341 mg/L Ref. 18, pp. 94, 97

Phenanthrene 20126-01 24” LINE 

BREAKS

0.0043 J ÷ 10

= 0.00043

mg/L Ref. 18, pp. 94, 97

Pyrene 20126-01 24” LINE 

BREAKS

0.0029 J ÷ 

11.86 = 0.00024

mg/L Ref. 18, pp. 94, 97

MCC Tank Samples

Acetone East Digester 0.51 E mg/L Ref. 18, pp. 31, 35

Carbon Disulfide East Digester 0.032 mg/L Ref. 18, pp. 31, 35

Methyl acetate East Digester 0.020 mg/L Ref. 18, pp. 31, 35

2-Butanone East Digester 0.20 E mg/L Ref. 18, pp. 31, 35

4-Methyl-2-pentanone 

(MIBK)

East Digester 0.018 mg/L Ref. 18, pp. 31, 35

Acetone East Clarifier 3.6 ED mg/L Ref. 18, pp. 39, 43

Carbon Disulfide East Clarifier 0.068 mg/L Ref. 18, pp. 39, 43

Methyl acetate East Clarifier 0.048 mg/L Ref. 18, pp. 39, 43

2-Butanone East Clarifier 0.43 mg/L Ref. 18, pp. 39, 43

4-Methyl-2-pentanone 

(MIBK)

East Clarifier 0.030 J mg/L Ref. 18, pp. 39, 43

Acetone West Clarifier 1.5 mg/L Ref. 18, pp. 47, 51

Carbon Disulfide West Clarifier 0.25 mg/L Ref. 18, pp. 47, 51

Methyl acetate West Clarifier 0.030 mg/L Ref. 18, pp. 47, 51

2-Butanone West Clarifier 0.210 mg/L Ref. 18, pp. 47, 51
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Hazardous

Substance

Evidence

Sample ID Concentration References 1 Units

Acetone West Digester 0.48 mg/L Ref. 18, pp. 55, 59

Carbon Disulfide West Digester 0.07 mg/L Ref. 18, pp. 55, 59

Methyl acetate West Digester 0.051 mg/L Ref. 18, pp. 55, 59

2-Butanone West Digester 0.420 mg/L Ref. 18, pp. 55, 59

Acetone Lift Station 6.5 ED mg/L Ref. 18, pp. 79, 83

Carbon Disulfide Lift Station 0.039 mg/L Ref. 18, pp. 79, 83

Methyl acetate Lift Station 0.083 mg/L Ref. 18, pp. 79, 83

2-Butanone Lift Station 0.86 ED mg/L Ref. 18, pp. 79, 83

Benzene Lift Station 0.028 mg/L Ref. 18, pp. 79, 83

4-Methyl-2-pentanone 

(MIBK)

Lift Station 0.130 mg/L Ref. 18, pp. 79, 83

Ethylbenzene Lift Station 0.031 mg/L Ref. 18, pp. 79, 83

m/p Xylene Lift Station 0.110 mg/L Ref. 18, pp. 79, 83

o Xylene Lift Station 0.061 mg/L Ref. 18, pp. 80, 83

Note:

J = Indicates estimated value (Ref. 18, p. 92).

RL = Reporting Limit (Ref. 18, p. 92).

1

Hazardous

Substance

= The Lab Sample ID name is identified as “UNKNOWN, NA 26” in reference 18.

In January 2010, an investigator with the TCEQ Water Quality Pretreatment Program observed 

unpermitted discharges into Vince Bayou from the USOR property (Ref. 6, p. 18). A violation was 

issued due to failure to prevent the unauthorized discharge of wastewater into the waters of the State. 

Wastewater was discharging from the old chlorine contact tank to Vince Bayou from two unpermitted 

outfalls. Two separate discharges were observed from the two outfall pipes located downstream of an 

old chlorine contact chamber. The two old outfall pipes are adjacent to each other; both pipes are 

located at the east plant of the MCC property and both pipes discharge to Vince Bayou (Ref. 6, p. 18; 

Ref. 12, p. 25; Ref. 54). The wastewater discharging into the bayou was sampled on 8 January 2010 

(labeled Discharge to Bayou) and 13 January 2010 (44028-01 and -02) (Ref. 12, p. 21). Analytical 

results indicated that acetone, arsenic, manganese, mercury and zinc was present in the discharge as 

shown in the table below (Ref. 6, pp. 18, 664-665; Ref. 12, pp. 24, 25, 27, 28, 29, 35-37, 49, 53, 54, 

64-68).

Evidence

Sample ID Concentration Units References

TCEQ Investigation – January 2010

Arsenic Discharge to Bayou 0.023 mg/L Ref. 12, pp. 28, 29

Manganese Discharge to Bayou 0.346 mg/L Ref. 12, pp. 28, 29

Mercury Discharge to Bayou 0.001 mg/L Ref. 12, pp. 28, 29

Zinc Discharge to Bayou 1.59 mg/L Ref. 12, pp. 28, 29

Acetone Discharge to Bayou 15.5 mg/L Ref. 12, pp. 36, 39

Acetone 44028-01 2.5 mg/L Ref. 12, pp. 49, 52, 53

Acetone 44028-02 0.843 mg/L Ref. 12, pp. 52, 54
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During EPA ER activities in July 2010, sources overflowing into the floodwater were observed. EPA 

and TCEQ observed an uncontrolled release of liquids from the containment pond, secondary 

containments, and roll-off boxes labeled as containing hazardous waste, as well as from the surface 

impoundments located at the 200 N. Richey property (Ref. 7, pp. 3, 6). On 2 July 2010, the site 

received approximately 7 to 12 inches of rain. At one point during the day, North Richey Street 

directly in front of the site access was covered by over 4 feet of water, and Vince Bayou has raised to 

within 15 feet of the property fence line (Ref. 7, p. 3). The roll-off boxes labeled “Hazardous Waste” 

were observed leaking and the hazardous waste was in direct contact with the storm water which 

flowed down the main driveway of the USOR property, flowing across Richey St. and entering Vince 

Bayou (Ref. 6, pp. 64, 65, 111). The roll-off boxes were known to contain hazardous waste since they 

were sampled 16 October 2009 (RB-0325226 and RB-0325215) (Ref. 8, p. 5). Sampling results were 

received from Accutest Laboratories on 30 October 2009. The sample results showed the roll-off 

boxes were hazardous for benzene (D018) and 1,2-dichloroethane (D028) as shown in the table below

(Ref. 8, pp. 6, 176, 180, 195). Floodwater during EPA ER activities in July 2010 documented flooding 

of the USOR site and direct contact of the sources located on the property with the floodwaters 

entering Vince Bayou (Ref. 6, pp. 64-67, 108-114, 116-127).

Hazardous

Substance

Evidence

Sample ID Concentration RL Units References

TCEQ Investigation – January 2010

Benzene RB-0325226 0.624 0.13 mg/L Ref. 8, pp. 176, 195

1,2-Dichloroethane RB-0325226 0.835 0.13 mg/L Ref. 8, pp. 176, 195

Benzene RB-0325215 1.16 0.13 mg/L Ref. 8, pp. 180, 195

1,2-Dichloroethane RB-0325215 0.778 0.13 mg/L Ref. 8, pp. 180, 195

Note:

These concentrations were reported from the TCLP Leachate of the sample.

In addition to the events above, in December 2009, EPA inspectors observed the stormwater basin 

overflowing with an oily sheen and discharging into Vince Bayou (Ref. 9. p. 16). On 14 December, 

2009, EPA inspectors observed a waste delivery truck leaking D001 (characteristic hazardous waste 

for ignitibility) hazardous waste from a discharge valve into the stormwater basin or containment pond 

(Ref. 5, p. 288; Ref. 9, p. 16). 

Chemical Analysis

Surface water and sediment samples were collected during the March 2011 supplemental sampling 

activities conducted by EPA START-3 (Ref. 44, p. 4). A total of 21 surface water and sediment 

samples were collected from the surface water pathway at 19 locations within Vince and Little Vince

Bayous. The 21 samples includes 2 duplicate samples collected from the same location as the parent 

sample. In addition, to demonstrate overland flow and migration of contamination from on-site

sources, seven soil samples were collected along the overland flow pathways (Ref. 28, p. 6; Ref. 29, p. 

12, 14 20; Ref. 44, p. 4). Sample locations are depicted in Figure A-5 of Attachment A. 
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Background Concentrations:

Background surface water and sediment samples were collected from the locations described below to 

investigate whether a release from the site could be established (Ref. 44, p. 4).

• Vince Bayou - A background surface water and sediment sample was collected from Vince

Bayou (BG-02) immediately upgradient of the property at 200 N. Richey Street (Attachment A, 

Figure A-5; Ref. 28, p. 70). The background surface water and sediment sample collected from 

Vince Bayou will be compared to site-related surface water and samples collected from Vince 

Bayou.

• Little Vince Bayou – A background surface water and sediment sample was collected within 

Little Vince Bayou (BG-01) immediately upgradient of its confluence with Vince Bayou

((Attachment A, Figure A-5; Ref. 28, p. 72). The background surface water and sediment

sample collected from Little Vince Bayou will be compared to site-related surface water and 

sediment samples collected from Vince Bayou downstream of the Little Vince Bayou and 

Vince Bayou confluence.

The background surface water and sediment samples were collected on 01 and 03 March 2011 by EPA 

START-3. The surface water samples were collected from shallow depths by submerging the sample 

container into the water. The mouth of the sample container was positioned so that it faced upstream, 

while the sampling personnel stood downstream so as not to stir up sediment that could potentially 

contaminate the sample. The sediment samples were collected with disposable plastic scoops and 

homogenized in plastic bags. The homogenized sample was then transferred to an 8-ounce sample 

container. The samples were collected from 0 to 1 inch from below ground surface from locations 

within the bayou where sediments had accumulated such as bends in the bayou (Ref. 29, pp. 99, 101-

103; Ref. 44, p. 4). Once collected, both surface water and sediment sample bottles were placed on ice

until shipping (Ref. 29, pp. 17, 22, 49; Ref. 44, p. 5).The background samples (surface water and 

sediment) and the samples collected to demonstrate the presence of contamination in the overland flow 

path and to demonstrate an observed release were all collected during the same time frame during the 

same sampling event (Ref. 44, p. 4). The samples were collected by the same field team during the 

same sampling event, following the same sample collection protocols and methodologies. Background 

samples were collected from similar locations, were from similar media, same depth, used the same 

sampling methods, preservation, and handling and were all collected during the same weather 

conditions as the observed release samples (Ref. 28, pp. 68-75; Ref. 29; Ref. 44, pp. 1-5).

Sediment samples for organic analysis were hand delivered to the EPA Region 6 Environmental 

Services Branch Laboratory for analysis of VOCs and SVOCs. Surface water samples for organic 

analysis were shipped via Federal Express to the Datachem laboratory located in Salt Lake City, Utah,

for VOC and SVOC analysis under the Contract Laboratory Program (CLP). Surface water and 

sediment samples for inorganic analysis were shipped via Federal Express to the Sentinel laboratory

located in Huntsville, Alabama for metals analysis under the CLP The samples were analyzed for 

VOCs and SVOCs by CLP OLM04.2 and for TAL metals and mercury by CLP ISM01.2 (Ref. 24, pp. 

320-327; Ref. 29, p. 19; Ref. 30, p. 68; Ref. 38, p. 16; Ref. 39, p. 35). 
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EPA Supplemental Sampling Event - Background Sample Descriptions

March 2011

Station Location

(Sample ID.) Sample Location Sample Date (Military Time) Reference

Surface Water

BG-02

(F3SD9/MF3SD9)

Vince Bayou upgradient of USOR 

property at 200 N. Richey Street 

(south of W. Richey Street)

03/02/2011

(1112)

Ref. 30, pp. 47, 49; Ref. 28, p. 68; Ref. 

44, p. 4;Attachment A, Figure A-5

BG-01

(F3SJ6/MF3SJ6)

Little Vince Bayou upgradient of its 

confluence with Vince Bayou

03/03/2011

(1330)

Ref. 38, p. 16; Ref. 28, p. 72: Ref. 44, p. 

4; Attachment A, Figure A-5

Sediment

BG-02

(BG-02-03-

51/MF3SF3)

Vince Bayou upgradient of USOR 

property at 200 N. Richey Street 

(south of W. Richey Street)

03/02/2011

(1050)

Ref. 24, p. 322; Ref. 28, p. 68; Ref. 40, p. 

27; Ref. 44, p. 4;Attachment A, Figure A5

BG-01

(BG-01-03-

51/MF3SJ5)

Little Vince Bayou upgradient of its 

confluence with Vince Bayou

03/03/2011

(1330)

Ref. 24, p.324; Ref. 28, p. 72: Ref. 41, p. 

18; Ref. 44, p. 4; Attachment A, Figure 

A-5
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EPA Supplemental Sampling Event - Background Sample Concentrations

March 2011

Summary of USOR Designated Background Levels

Hazardous 

Substance Evidence Reference

Station 

Location/

Sample ID

Concentration

RL 

and 

CRQL 1

Surface Water – Vince Bayou, BG-02 mg/L mg/L

Arsenic MF3SD9 0.0149 J+ 0.001 Ref. 42, pp. 5 13, 25, 38

Barium MF3SD9 0.0728 0.01 Ref. 42, pp. 5 13, 25, 38

Lead MF3SD9 0.0016 J+ 0.001 Ref. 42, pp. 5 13, 25, 38

Manganese MF3SD9 0.0426 0.001 Ref. 42, pp. 5, 13, 25, 38

Nickel MF3SD9 0.0039 0.001 Ref. 42, pp. 5 13, 25, 38

Silver MF3SD9 0.0017 J+ 0.001 Ref. 42, pp. 5 13, 25, 38

Zinc MF3SD9

0.0141 J-

(0.018189) 0.002 2 Ref. 21, pp. 8, 18; Ref. 42, 

pp. 5, 13, 25, 38

Surface Water – Little Vince Bayou, BG-01 mg/L mg/L

Chloroform F3SJ6 0.00057 0.0005 Ref. 39, pp. 19, 35, 105

Arsenic MF3SJ6 0.021 J 0.002 Ref. 38, pp. 13,16, 32

Barium MF3SJ6 0.0582 J 0.010 Ref. 38, pp. 13,16, 32

Manganese MF3SJ6 0.0352 0.002 Ref. 38, pp. 13,16, 32

Zinc MF3SJ6 0.0201 J 0.004 Ref. 38, pp. 13,16, 32

Sediment – Vince Bayou, BG-02 mg/kg mg/kg

Benzo(a)anthracene BG-02-03-51 1.16 0.694 Ref. 24, pp. 75, 322

Benzo(a)pyrene BG-02-03-51 1.74 0.694 Ref. 24, pp. 75, 322

Benzo(b)fluoranthene BG-02-03-51 1.9 0.694 Ref. 24, pp. 75, 322

Benzo(g,h,i)perylene BG-02-03-51 1.37 0.694 Ref. 24, pp. 75, 322

Benzo(k)fluoranthene BG-02-03-51 1.39 0.694 Ref. 24, pp. 75, 322

Bis(2-ethylhexyl)phthalate BG-02-03-51 0.694 U 0.694 Ref. 24, pp. 75, 322

Chrysene BG-02-03-51 1.75 0.694 Ref. 24, pp. 76, 322

Fluoranthene BG-02-03-51 2.53 0.278 Ref. 24, pp. 76, 322

Indeno(1,2,3-cd)pyrene BG-02-03-51 1.16 0.694 Ref. 24, pp. 76, 322

2-Methylnaphthalene BG-02-03-51 0.278 U 0.278 Ref. 24, pp. 76, 322

Naphthalene BG-02-03-51 0.278 U 0.278 Ref. 24, pp. 76, 322

Phenanthrene BG-02-03-51 0.750 0.278 Ref. 24, pp. 77, 322

Pyrene BG-02-03-51 2.74 0.278 Ref. 24, pp. 77, 322

Arsenic MF3SF3 2.3 J 0.70 Ref. 40, pp. 8, 17, 27, 60

Barium MF3SF3 81.0 7.0 Ref. 40, pp. 8, 17, 27, 60

Chromium MF3SF3 16.2 J 1.4 Ref. 40, pp. 8, 17, 27, 60

Cobalt MF3SF3 4.3 J 0.70 Ref. 40, pp. 8, 17, 27, 60

Copper MF3SF3 16.7 J 1.4 Ref. 40, pp. 8, 17, 27, 60

Lead MF3SF3 50.5 J 0.70 Ref. 40, pp. 8, 17, 27, 60

Manganese MF3SF3 158 J 0.70 Ref. 40, pp. 8, 17, 27, 60

Mercury MF3SF3 0.076 LJ 0.14 Ref. 40, pp. 8, 17, 27, 59

Silver MF3SF3 0.70 U 0.70 Ref. 40, pp. 8, 17, 27, 60

Nickel MF3SF3 7.8 J 0.70 Ref. 40, pp. 8, 17, 27, 60

Vanadium MF3SF3 16.1 J 3.5 Ref. 40, pp. 8, 17, 27, 60

Zinc MF3SF3 74.0 J- (111) 1.4 2 Ref. 21, pp. 8, 18; Ref. 40, 

pp. 8, 17, 27, 60
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Summary of USOR Designated Background Levels

Hazardous 

Substance Evidence Reference

Station 

Location/

Sample ID

Concentration

RL 

and 

CRQL 1

Sediment – Little Vince Bayou, BG-01 mg/kg mg/kg

Bis(2-ethylhexyl)phthalate BG-01-03-51 0.629 U 0.629 Ref. 24, pp. 120, 324

2-Methylnaphthalene BG-01-03-51 0.252 U 0.252 Ref. 24, pp. 121, 324

Naphthalene BG-01-03-51 0.252 U 0.252 Ref. 24, pp. 121, 324

Arsenic MF3SJ5 2.3 J 0.65

Ref. 41, pp. 3-11, 14, 

18,45

Barium MF3SJ5 196 6.5

Ref. 41, pp. 3-11, 14, 

18,45

Beryllium MF3SJ5 0.81 J 0.65

Ref. 41, pp. 3-11, 14, 

18,45

Chromium MF3SJ5 12.4 1.3

Ref. 41, pp. 3-11, 14, 

18,45

Cobalt MF3SJ5 4.3 J 0.65

Ref. 41, pp. 3-11, 14, 

18,45

Copper MF3SJ5 5.9 J 1.3

Ref. 41, pp. 3-11, 14, 

18,45

Lead MF3SJ5 10.3 0.65

Ref. 41, pp. 3-11, 14, 

18,45

Manganese MF3SJ5 148 J 0.65

Ref. 41, pp. 3-11, 14, 

18,45

Mercury MF3SJ5 0.0083 LJ 0.13

Ref. 41, pp. 3-11, 14, 

18,44

Silver MF3SJ5 0.65 U 0.65

Ref. 41, pp. 3-11, 14, 

18,44

Nickel MF3SJ5 9.5 J 0.65

Ref. 41, pp. 3-11, 14, 

18,45

Vanadium MF3SJ5 20.1 J 3.3

Ref. 41, pp. 3-11, 14, 

18,45

Zinc MF3SJ5 16.9 J 1.3

Ref. 41, pp. 3-11, 14, 

18,45

Notes:

1

 The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory and the Adjusted Contract Required Quantitation Limit (CRQL) 

terminology used by the CLP Laboratory are both detection limits which have been adjusted for sample aliquot, sample volume, and dilutions for the 

analysis and meet the HRS definition of SQL (Ref. 1, Section 1.1, Table 2-3; Ref. 24, p. 4; Ref. 26). 2

- Low biased (Ref. 38, p. 11, Ref. 40, p. 11, Ref. 41, p. 11, Ref. 42, p. 12).

 Values that have been adjusted according to the EPA Fact Sheet (Reference 21) are listed in parentheses.

U Not detected at reported quatitation limit (Ref. 42, p. 12).

J Result is estimated because of outlying quality control parameters or the result is below the CRQL (Ref. 38, p. 11, Ref. 40, p. 11, Ref. 41, p. 11, Ref. 

42, p. 12).

L Reported concentration between the MDL and the CRQL (Ref. 38, p. 11, Ref. 40, p. 11, Ref. 41, p. 11, Ref. 42, p. 12).

+ High biased (Ref. 38, p. 11, Ref. 40, p. 11, Ref. 41, p. 11, Ref. 42, p. 12).
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Samples collected from Vince Bayou above and below the confluence of Little Vince Bayou will be 

compared against the highest designated background levels as shown below: 

Surface Water 

Body Matrix Hazardous 

Substance

Highest 

Background 

Concentration

Background Comparison 

Conc.

3 x Background or 

RL/CRQL

Vince Bayou Surface Water Arsenic

Barium

Iron

Lead

Manganese

Nickel

Silver

Zinc

0.0149 mg/L

0.0728 mg/L

0.160 J mg/L

0.0016 mg/L

0.0426 mg/L

0.0039 mg/L

0.0017 mg/L

0.018189 mg/L

0.0447 mg/L

0.2184 mg/L

0.20 mg/L

0.0048 mg/L

0.1278 mg/L

0.0117 mg/L

0.0051 mg/L

0.054567 mg/L

Little Vince Bayou Surface Water Chloroform

Arsenic

Barium

Manganese

Zinc

0.00057 mg/L

0.021 J mg/L

0.0582 J mg/L

0.0352 mg/L

0.0201 J mg/L

0.00171 mg/L

0.063 mg/L

0.1746 mg/L

0.1056 mg/L

0.0603 mg/L

Vince Bayou Sediment Benzo(a)anthracene

Benzo(a)pyrene

Benzi(b)fluoranthene

Benzo(g,h,i)perylene

Benzo(k)fluoranthene

Bis(2-ethylhexyl)phthalale

Chrysene

Fluoranthene

Indeno(1,2,3-cd)pyrene

2-Methylnaphthalene

Naphthalene

Phenanthrene

Pyrene

Arsenic

Barium

Chromium

Cobalt

Copper

Iron

Lead

Manganese

Mercury

Silver

Nickel

Vanadium

Zinc

1.16 mg/kg

1.74 mg/kg

1.9 mg/kg

1.37 mg/kg

1.39 mg/kg

0.694 U mg/kg

1.75 mg/kg

2.53 mg/kg

1.16 mg/kg

0.278 U mg/kg

0.278 U mg/kg

0.75 mg/kg

2.74 mg/kg

2.3 mg/kg

81 mg/kg

16.2 mg/kg

4.3 mg/kg

16.7 mg/kg

12,600 mg/kg

50.5 mg/kg

158 mg/kg

0.076 J mg/kg

0.70 U mg/kg

7.8 mg/kg

16.1 mg/kg

111 mg/kg

3.48 mg/kg

5.22 mg/kg

5.7 mg/kg

4.11 mg/kg

4.17 mg/kg

0.0694 mg/kg

5.25 mg/kg

7.59 mg/kg

3.48 mg/kg

0.278 mg/kg

0.278 mg/kg

2.25 mg/kg

8.22 mg/kg

6.9 mg/kg

243 mg/kg

448.6 mg/kg

12.9 mg/kg

50.1 mg/kg

37,800 mg/kg

151.5 mg/kg

474 mg/kg

.228 mg/kg

0.70 mg/kg

23.4 mg/kg

48.3 mg/kg

333 mg/kg
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Surface Water 

Body Matrix Hazardous 

Substance

Highest 

Background 

Concentration

Background Comparison 

Conc.

3 x Background or 

RL/CRQL

Little Vince Bayou Sediment Bis(2-ethylhexyl)phthalate

2-Methylnaphthalene

Naphthalene

Arsenic

Barium

Beryllium

Chromium

Cobalt

Copper

Iron

Lead

Manganese

Mercury

Nickel

Silver

Vanadium

Zinc

0.629 U mg/kg

0.252 U mg/kg

0.252 U mg/kg

2.3 mg/kg

196 mg/kg

0.81 mg/kg

12.4 mg/kg

4.3 mg/kg

5.9 mg/kg

15,200 mg/kg

10.3 mg/kg

148 mg/kg

0.0083 LJ mg/kg

9.5 mg/kg

0.65 U mg/kg

20.1 mg/kg

16.9 mg/kg

0.629 mg/kg

0.252 mg/kg

0.252 mg/kg

6.9 mg/kg

588 mg/kg

2.43 mg/kg

37.2 mg/kg

12.9 mg/kg

17.7 mg/kg

45,600 mg/kg

30.9 mg/kg

444 mg/kg

0.13 mg/kg

28.5 mg/kg

0.65 mg/kg

60.3 mg/kg

50.7 mg/kg

Notes: 

U Not detected at reported quatitation limit (Ref. 42, p. 12).

J Result is estimated because of outlying quality control parameters (Ref. 42, p. 12).

L Reported concentration between the MDL and the CRQL (Ref. 42, p. 12).
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Observed Release Samples:

Samples identified as “contaminated” are those that meet observed release criteria as defined by the 

HRS (Ref. 1, Table 2-3). Observed release criteria is met when the hazardous substance is attributable 

to a release from the site, its concentration exceeds the SQL(including the background SQL), and is at 

least three times greater than the background concentration when the background concentration equals 

or exceeds its SQL (Ref. 1, Table 2-3). Sampling locations with hazardous substances meeting 

observed release criteria are presented below.

EPA Supplemental Sampling Event – March 2011

Station Location

(Sample ID) Sample Location Sample Date (Military Time) Reference

Vince Bayou

SW-01

(SED-01-03-51)

Furthest downstream sample located in Vince 

Bayou, 190 feet downstream of PPE-01

03/02/2011

(1537)

Ref. 24, p. 323; Ref. 28, p. 71;

Ref. 34

SW-02

(MF3SG4) 90 feet downstream of PPE-01 in Vince Bayou 03/02/2011(1600)

Ref. 28, p. 71;Ref. 34; Ref. 40, p. 

25

PPE-01

(MF3SH3/MF3SH2)

Furthest downstream PPE into Vince Bayou from 

northern end of 400 N. Richey Street property

03/03/2011

(0927/0929)

Ref. 28, p. 72;Ref. 34; Ref. 41, 

pp. 17, 18

SW-03

(MF3SH5/MF3SH4)

150 feet upgradient from PPE-01 and 440 feet 

downstream of PPE-02 in Vince Bayou

03/03/2011

(0950/0954

Ref. 28, p. 72;Ref. 34; Ref. 42,

pp. 29, 30

SW-04

(MF3SH7/MF3SH6)

340 feet upgradient from PPE-01and 250 feet 

downstream of PPE-02 in Vince Bayou

03/03/2011

(0927/0929)

Ref. 28, p. 72;Ref. 34; Ref. 41, 

pp. 17, 18; 

PPE-02

(MF3SH9)

PPE from northeast corner of 400 N. Richey 

Street property into Vince Bayou

03/03/2011

(1037)

Ref. 28, p. 72;Ref. 34; Ref. 41, p. 

17

SW-07 

(PPE-02A/MF3SG9)

PPE from drainage ditch along 400 N. Richey 

Street property into Vince Bayou

03/02/2011

(0839)

Ref. 28, p. 71;Ref. 34; Ref. 41, p. 

18

PPE-03

MF3SG0/PPE-03-03-

51/MF3SG1)

PPE from entrance drive of 400 N. Richey Street

property into Vince Bayou

03/02/2011

(1442/1447)

Ref. 24, p. 323; Ref. 28, p. 

70;Ref. 34; Ref. 40 , p. 25

SW-08

(MF3SJ0)

215feet upgradient from PPE-03 and 150 feet 

downstream of PPE-04 in Vince Bayou

03/03/2011

(1122)

Ref. 28, p. 72;Ref. 34; Ref. 41, p. 

17

PPE-04

(MF3SF8/PPE-04-03-

51)

PPE from southeastern edge of 400 N. Richey 

Street property into Vince Bayou

03/02/2011

(1407/1412)

Ref. 24, p. 323; Ref. 28, p. 

70;Ref. 34; Ref.42, p. 28

SW-09

(MF3SF7/MF3SF6)

125 feet upgradient from PPE-04 and 330 feet 

downstream of PPE-05 in Vince Bayou

03/02/2011

(1344/1350)

Ref. 28, p. 70;Ref. 34; Ref. 40, p. 

27

PPE-05

(MF3SE3/MF3SE4/PP

E-05-03-51)

PPE from eastern side of 200 N. Richey Street

property into Vince Bayou

03/01&02/2011

(1442/0937)

Ref. 24, p. 322; Ref. 28, pp. 69, 

70;Ref. 34; Ref. 42, p. 26

SW-10

(MF3SE6/MF3SE7/M

F3SE8)

385 feet upgradient from PPE-04 and 70 feet 

downstream of PPE-05 in Vince Bayou

03/02/2011

(1305/0845)

Ref. 28, p. 70;Ref. 34; Ref. 42, p. 

26

PPE-06

(MF3SE1/PPE-06-03-

51)

PPE from western side of N. Richey Street

property into Vince Bayou

03/01&02/2011

1325/1006)

Ref. 24, p. 322; Ref. 28, pp. 69, 

70;Ref. 34; Ref. 42, p. 26

SW-11 (PPE-06A)

(MF3SE0/SED-11-3-

51)

Furthest upgradient PPE from southern end of 200 

N. Richey Street property 

03/01&02/2011

(1305/1107)

Ref. 24, p. 322; Ref. 28, pp. 69, 

70;Ref. 34; Ref. 42, p. 26
SW Pathway – Likelihood of Release

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The surface water and sediment samples were collected on 01 and 03 March 2011 by EPA START-3. 

The surface water samples were collected from shallow depths by submerging the sample container 

into the water. The mouth of the sample container was positioned so that it faced upstream, while the 

sampling personnel stood downstream so as not to stir up sediment that could potentially contaminate 

the sample. The sediment samples were collected with disposable plastic scoops and homogenized in 

plastic bags. The homogenized sample was then transferred to an 8-ounce sample container. The 

samples were collected from 0 to 1 inch from below ground surface from locations within the bayou 

where sediments had accumulated such as bends in the bayou (Ref. 29, pp. 99, 101-103; Ref. 44, p. 4). 

Once collected, both surface water and sediment sample bottles were placed on ice until shipping (Ref. 

29, pp. 17, 22, 49; Ref. 44, p. 5).

Sediment samples for organic analysis were hand delivered to the EPA Region 6 Environmental 

Services Branch Laboratory for analysis of VOCs and SVOCs. Surface water samples for organic 

analysis were shipped via Federal Express to the Datachem laboratory located in Salt Lake City, Utah,

for VOC and SVOC analysis under the Contract Laboratory Program (CLP). Surface water and 

sediment samples for inorganic analysis were shipped via Federal Express to the Sentinel laboratory

located in Huntsville, Alabama for metals analysis under the CLP. The samples were analyzed for 

VOCs and SVOCs by CLP OLM04.2 and for TAL metals and mercury by CLP ISM01.2 (; Ref. 38, p. 

16; Ref. 24, pp. 320-327; Ref. 30, pp. 47-53; Ref. 39, pp. 34-37; Ref. 44, p. 5)

EPA Supplemental Sampling Event – March 2011

Surface Water Samples – Vince Bayou

Station Location

(Sample ID)

Hazardous

Substance

Concentration Adjusted 

CRQL

2

mg/L

1

mg/L

Reference

SW-03

(MF3SH4) Lead 0.016 0.001 Ref. 42, pp. 5 19, 30, 55

Notes: 1 The Adjusted Contract Required Quantitation Limit (CRQL) terminology used by the CLP Laboratory is detection limits which have been adjusted 

for sample aliquot, sample volume, and dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Section 1.1,, Table 2-3; Ref. 24, p. 

3; Ref. 26).
SW Pathway – Likelihood of Release

HRS Documentation Record 83 US Oil Recovery

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EPA Supplemental Sampling Event – March 2011

Sediment Samples – Vince Bayou

Station Location

(Sample ID)

Hazardous

Substance

Concentration

mg/kg

Adjusted 

CRQL1

mg/kg

Reference

SW-01

(SED-01-03-51) Bis(2-ethylhexyl)phthalate 0.904 B 0.695 Ref. 24, pp. 80, 323

SW-01

(MF3SG2) Arsenic 13.1 J 0.82 Ref. 40, pp. 8, 19, 25

SW-02

(MF3SG4)

Arsenic 11.8 J 0.68 Ref. 40, pp. 8, 19, 25, 74

Mercury 0.92 0.14 Ref. 40, pp. 8, 19, 25, 73

SW-03

(MF3SH5)

Mercury 0.32 0.17 Ref. 41, pp. 8, 13, 18, 34

Silver 1.7 0.87 Ref. 41, pp. 8, 13, 18, 35

SW-04

(MF3SH6)

Arsenic 19.3 J 0.67 Ref. 41, pp. 8, 13, 18, 37

Mercury 1.8 0.13 Ref. 41, pp. 8, 13, 18, 36

SW-08

(MF3SJ0)

Barium 291 8.2 Ref. 41, pp. 8, 14, 17, 41

Lead 196 1.6 Ref. 41, pp. 8, 14, 17, 41

Mercury 0.81 0.16 Ref. 41, pp. 8, 14, 17, 40

Silver 7.9 0.82 Ref. 41, pp. 8, 14, 17,41

SW-09

(MF3SF6)

Mercury 0.33 0.14 Ref. 40, pp. 8, 18, 27, 65

Silver 1.8 0.69 Ref. 40, pp. 8, 18, 27, 66

SW-10

(MF3SE8)

Cobalt 26.7 J 3.4 Ref. 40, pp. 8, 15, 26, 52

Manganese 1,030 J 3.4 Ref. 40, pp. 8, 15, 26, 52

Vanadium 48.7 J 17 Ref. 40, pp. 8, 15, 26, 52

SW-11

(SED-11-03-51)

Bis

(2-ethylhexyl)phthalate 0.563 B 0.550 Ref. 24, p. 105, 322

PPE-01

(MF3SH2)

Arsenic 10.3 J 0.67 Ref. 41, pp. 8, 12, 17, 33

Mercury 0.35 0.13 Ref. 41, pp. 8, 12, 17, 32

Silver 1.0 0.67 Ref. 41, pp. 8, 12, 17, 33

PPE-02

(MF3SH9)

Mercury 0.32 0.16 Ref. 41, pp. 8, 13, 17, 38

Silver 2.3 0.79 Ref. 41, pp. 8, 13, 17, 39

PPE-03

(PPE-03-03-51)

Carbon disulfide 0.146 B 0.1 Ref. 24, pp. 48, 323

Bis

(2-ethylhexyl)phthalate 7.45 0.772 Ref. 24, pp. 50, 323

PPE-03

(MF3SG1) Silver 1.1 0.85 Ref. 40, pp. 8, 18, 25, 70

PPE-04

(PPE-04-03-51)

Bis

(2-ethylhexyl)phthalate 1.21 0.721 Ref. 24, pp. 55, 323

PPE-05

(PPE-05-03-51)

Bis

(2-ethylhexyl)phthalate 1.88 1.01 Ref. 24, pp. 60, 322

2-Methlynaphthalene 0.544 0.406 Ref. 24, pp. 61 ,322

Naphthalene 0.416 0.406 Ref. 24, pp. 61, 322

PPE-05 field 

duplicate

(PPE-05-03-52)

Bis

(2-ethylhexyl)phthalate 1.97 0.776 Ref. 24, pp. 65, 322

PPE-06

(MF3SF5/ PPE06-03-51)

Bis

(2-ethylhexyl)phthalate 1.95 0.831 Ref. 24, pp. 70, 322

Notes:

 1

B Blank related – the concentration found in the sample was less than 10x the concentration found in the associated extraction, digestion and/or analysis 

The Adjusted Contract Required Quantitation Limit (CRQL) terminology used by the CLP Laboratory is detection limits which have been adjusted for 

sample aliquot, sample volume, and dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Section 1.1, Table 2-3; Ref. 24, p. 3; Ref. 

26).
SW Pathway – Likelihood of Release 

HRS Documentation Record 84 US Oil Recovery 

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blank (Ref. 24, p. 328). 

J Result is estimated because of outlying quality control parameters (Ref. 40, p. 11, Ref. 41, p. 11). 

Attribution:

 

Attribution generally involves demonstrating that the hazardous substances used to establish an 

observed release can be associated with the site, and the site contributed at least in part to the 

significant increase in the concentration of the hazardous substances. Although USOR and MCC 

Recycling were evaluated as separate sites in the TCEQ Preliminary Assessments (Ref. 5, pp. 10, 11; 

Ref, 6, pp. 10, 11), it has been demonstrated that these properties are one site since they are owned by 

the same individual, their operations are interconnected, they have similar waste sources including that 

waste from the 400 N. Richey Street property is transported to the 200 N. Richey Street property via a 

pipeline, and they affect the same pathway targets (Ref. 9, p. 3; Ref. 11, pp. 1, 2; Ref. 12, p. 5). 

Association with Sources 

Sources containing hazardous substances and releases of hazardous substances from these sources 

have been documented at this site, as discussed in Section 2.2 Source Characterization of this HRS 

documentation record and Section 4.1.2.1.1 Observed Release of the HRS. Samples collected from 

overland drainage routes document hazardous substance migration from site sources to the surface 

water pathway (Ref. 29, p. 14). The following soil samples are included to support migration of siterelated contamination along the overland flow segments from the sources to the probable points of 

entry to Vince Bayou. 

Station Location 

(CLP Sample No.) Sampling Location Sample Date (Military Time) Reference

EPA Supplemental Sampling Event – March 2011

SS-01 

(MF3SD8) 

North of the 400 N. Richey Street 

property between the property boundary 

and PPE-01 into Vince Bayou 

03/01/2011 

(1022) 

Ref. 28, p. 68; Ref. 40, p. 24 ; 

Attachment A, Figure A-5 

SS-02 

(MF3SD7) 

North of the 400 N. Richey Street 

property between the property boundary 

and PPE-01 into Vince Bayou 

03/01/2011 

(1012) 

Ref. 28, p. 68; Ref. 40, p. 24; 

Attachment A, Figure A-5 

SS-03 

(MF3SD5) 

Northeast corner of the 400 N. Richey 

Street property between the property 

boundary and PPE-02 into Vince Bayou

03/01/2011 

(0948) 

Ref. 28, p. 68; Ref. 40, p. 23; 

Attachment A, Figure A-5 

SS-03 

field duplicate 

(MF3SD6) 

Northeast corner of the 400 N. Richey 

Street property between the property 

boundary and PPE-02 into Vince Bayou

03/01/2011 

(0955) 

Ref. 28, p. 68; Ref. 40, p. 23; 

Attachment A, Figure A-5 

SS-04 

(MF3SD4) 

East side of the 400 N. Richey Street 

property between property boundary and 

PPE-03 into Vince Bayou 

03/01/2011 

(0925) 

Ref. 28, p. 68; Ref. 40, p. 23; 

Attachment A, Figure A-5 

SS-05 

(MF3SD3) 

Southeast side of the 400 N. Richey 

Street property between the property 

boundary and PPE-04 into Vince Bayou

03/01/2011 

(0902) 

Ref. 28, p. 68; Ref. 40, p. 23; 

Attachment A, Figure A-5 

SS-06 

(MF3SD1) 

East side of western portion of 200 N. 

Richey Street property between the 

property boundary and PPE-06 into 

Vince Bayou 

03/01/2011 

(0833) 

Ref. 28, p. 68; Ref. 40, p. 23 ; 

Attachment A, Figure A-5 
SW Pathway – Likelihood of Release 

HRS Documentation Record 85 US Oil Recovery 

TXN000607093 

Station Location 

(CLP Sample No.) Sampling Location Sample Date (Military Time) Reference

SS-07 

(MF3SD2) 

West side of eastern portion of 200 N. 

Richey Street property between the 

property boundary and PPE-05 into 

Vince Bayou 

03/01/2011 

(0846) 

Ref. 28, p. 68; Ref. 40, p. 23; 

Attachment A, Figure A-5 

Analytical results from soil samples collected from overland flow pathways are included to support 

migration of site-related contamination at observed release concentrations along the overland flow 

segment from site source to the PPEs only. The analytical results from these samples were not used to 

score the site, but to support attribution. 

Station Location 

(CLP Sample No.)

Hazardous 

Substance

Concentration2

mg/kg

Adjusted 

CRQL1

mg/kg

Reference

EPA Supplemental Sampling Event – March 2011

SS-02 

(MF3SD7) Arsenic 11.9 J 1.3 Ref. 40, pp. 8, 15, 24, 48 

Arsenic 464 J 13 Ref. 40, pp. 8, 14, 23, 46 

Cobalt 57.7 13 Ref. 40, pp. 8, 14, 23, 46 

Manganese 3,600 J 13 Ref. 40, pp. 8, 14, 23, 46 

Mercury 0.16 0.13 Ref. 40, pp. 8, 14, 23, 45 

Nickel 30.9 J 13 Ref. 40, pp. 8, 14, 23, 46 

SS-03 field duplicate 

(MF3SD6) 

Vanadium 65.9 J 65 Ref. 40, pp. 8, 14, 23, 46 

Arsenic 205 J 3.3 Ref. 40, pp. 8, 14, 23, 44 

Cobalt 19.1 J 3.3 Ref. 40, pp. 8, 14, 23, 44 

Manganese 1,170 J 3.3 Ref. 40, pp. 8, 14, 23, 44 

SS-03 

(MF3SD5) 

Mercury 0.15 0.13 Ref. 40, pp. 8, 14, 23, 43 

SS-04 Antimony 1.8 J 1.7 Ref. 40, pp. 8, 14, 23, 42 

(MF3SD4) Arsenic 10.5 J 0.83 Ref. 40, pp. 8, 14, 23, 42 

SS-06 

(MF3SD1) Mercury 0.59 0.12 Ref. 40, pp. 8, 13, 23, 35 

SS-07 Mercury 0.66 0.12 Ref. 40, pp. 8, 13, 23, 37 

(MF3SD2) Silver 5.1 0.61 Ref. 40, pp. 8, 13, 23, 38 

Notes:

 1 The Adjusted Contract Required Quantitation Limit (CRQL) terminology used by the CLP Laboratory is detection limits which have been 

adjusted for sample aliquot, sample volume, and dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Section 1.1, Table 2-3; 

Ref. 24, p. 3; Ref. 26). 2

 The qualification did not indicate bias and did not require use of an adjustment factor (Ref. 40, p. 11; Ref. 21) 

J Result is estimated because of outlying quality control parameters or the result is below the CRQL (Ref 40, p. 11). 

Results of attribution soil samples revealed detects of several metals as shown above. Of the metals 

detected above in attribution soil samples, arsenic, mercury, silver, cobalt, manganese, and vanadium 

were also detected within Vince Bayou at concentrations meeting observed release criteria (Ref. 1, 

Table 2-3). Due to historical operations at the site (operations that have demonstrated to cause arsenic, 

barium, cobalt, manganese, mercury, silver, and vanadium contamination as shown through sampling 

results of sources) combined with the overall lack of containment of the sources at the site and the fact 

that sediment samples of overland flow pathways meeting observed release criteria are present which 

support arsenic, cobalt, manganese, mercury, silver, and vanadium contamination migration from 

sources at the site into the surface water pathway, the arsenic, cobalt, manganese, mercury, silver, and 
SW Pathway – Likelihood of Release 

HRS Documentation Record 86 US Oil Recovery 

TXN000607093 

vanadium contamination in sediments at the site can be attributed (wholly or, at least, in part) to the 

USOR site 

Consideration of Other Possible Off-Site Sources 

Although USOR is located in a highly industrialized area, the background samples collected at the site 

are deemed appropriate background samples for the purposes of evaluating the site under the EPA’s 

HRS as the analytical results from the background samples are indicative of the highly industrialized 

area. Samples meeting observed release criteria, or displaying concentrations that are three times 

greater than the highest background concentration of a particular analyte, were collected at the site and 

from within the surface water pathway. Further, analytical results from samples collected from the 

sources at the site displayed the presence of the same contaminants as the samples from the surface 

water pathway meeting observed release criteria. 

Downgradient sources were not evaluated as background. Although the surface water pathway 

includes water bodies which are tidally influenced there is no documentation to that there is tidal carry 

from other possible downgradient sources (Ref. 51, p. 1). The site is located approximately 18 stream 

miles from the coast and therefore only minimal elevation changes due to tidal influence are expected 

to occur (Ref. 3, pp. 1-3). 

A search of the Toxic Release Inventory and EPA EnviroMapper databases were performed within the 

zip code of the site location. The facilities identified upgradient along Vince Bayou included: 

Macdermid a facility that contains glycol ethers, diethanolamine and ethylene glycol; JE Merit 

Constructors, Inc. and inactive paper facility; Corrosion Fighters an inactive facility with no 

compliance history; Houston Tape and Label an inactive facility which produced labels; Naylor 

Industrial Services an inactive general freight trucking company; and Exxon Company an inactive 

petroleum facility. No nearby facilities along the surface water pathway have shown a release of 

arsenic, cobalt, manganese, mercury, silver, and vanadium (Ref. 50; Ref. 53, pp.1-6). 

Likelihood of Release Factor:

Based on the analytical data and attribution components listed above, arsenic, barium, cobalt, 

manganese, mercury, silver, and vanadium have been documented as the hazardous substances in the 

observed release to Vince Bayou. Therefore, the observed release factor value of 550 was assigned for 

Vince Bayou (Ref. 1, Section 4.1.2.1.1). 

Likelihood of Release Factor Value: 550 
SW Pathway – Potential to Release 

HRS Documentation Record 87 US Oil Recovery 

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4.3 POTENTIAL TO RELEASE

4.3.1 Potential to Release by Overland Flow

Potential to release was not evaluated because an observed release to surface water was established by 

direct observation and chemical analysis (see Section 4.1.2.1.1 of the HRS). 
SW Pathway –Human Food Chain Threat/Waste Characteristics 

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4.4 HUMAN FOOD CHAIN THREAT 

WASTE CHARACTERISTICS

Evidence of contamination associated with Sources 1 through 8 has been established based on 

chemical analyses of samples collected from these sources (refer to the Attribution section and Section 

2.2 for each source). Arsenic, barium, cobalt, manganese, mercury, silver, and vanadium were 

detected in sediment samples collected in Vince Bayou, thus establishing an observed release (see 

Section 4.1.2.1.1). The Vince Bayou has been documented to contain tidally influenced brackish 

water where the fishery and wetlands are located (Ref. 51, p. 1) 

4.4.1 Toxicity/Persistence/Bioaccumulation 

Hazardous 

Substance

Source 

Number

Toxicity

Factor 

Value

Persistence

Factor 

Value1

Bioaccumulation 

 Value 

Fresh2

Bioaccumulation 

 Value 

Salt2

Toxicity/ 

Persistence/ 

Bioaccumulation 

Factor Value Reference

Arsenic 3,4,7,OR 10,000 1 5 500 5 x 106 Ref. 2, p.1 

Bis(2-

ethylhexyl) 

phthalate 

2,4,6,OR 100 1 50,000 500 5 x 106 Ref. 2, p. 2 

Cobalt 1,4,5,6,8,

OR 

10 1 5,000 5,000 5 x 104 Ref. 2, p. 3 

Lead 3,4,5,6, 

OR 

10,000 1 5 5,000 5 x 107 Ref. 2, p. 8 

Manganese 1,2,4,5,6,

7,8, 

OR 

10,000 1 50,000 50,000 5 x 108 Ref. 2, p. 8 

Mercury 3,6,OR 10,000 1 50,000 50,000 5 x 108 Ref. 2, p. 8 

2-Methylnaphthalene 1,2,4,5,6,

8, OR 

0 0.4000 50,000 50,000 0 Ref. 2, p. 9 

Naphthalene 1,2,3,4,5,

6,8, 

OR 

1,000 0.4000 50,000 5,000 2 x 107 Ref. 2, p. 9 

Silver 3,4,OR 100 1 50 50,000 5 x 106 Ref. 2, p. 10 

Vanadium 3,4,5,6, 

7,OR 

100 1 500 500 5 x 104 Ref. 2, p. 11 

Notes:

OR – Observed Release 

1

 The surface water category that includes rivers, oceans, coastal tidal waters, and great lakes was utilized to assign the hazardous 

substances persistence factor value (Ref. 1, Sect. 4.1.2.2.1.2). The persistence values were assigned for a river according to HRS Section 

4.1.3.2.1.2. 

2

 Bioaccumulation factor values are assigned from the SCDM (Ref. 2), for both water body types "Fresh Water" and “Salt Water” in

which the fisheries are located. The data that yielded the higher factor value was assigned to the Bioaccumulation Factor Value of the 

hazardous substance (Ref. 1, Sect. 4.1.3.2.1.3). 

Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 108
SW Pathway –Human Food Chain Threat/Waste Characteristics 

HRS Documentation Record 89 US Oil Recovery 

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4.4.2 Hazardous Waste Quantity 

Source 

No.

Source Hazardous 

Waste Quantity 

Value

Containment

Ground Water Surface Water Gas Air Particulate

1 33.896 NE 9 NE NE 

2 1,173.333 NE 10 NE NE 

3 48.889 NE 10 NE NE 

4 2,605.912 NE 10 NE NE 

5 48.216 NE 9 NE NE 

6 67.337 NE 10 NE NE 

7 1,813.333 NE 10 NE NE 

TOTAL 5,790.916 

A hazardous waste quantity of 5,790.916 is estimated for sources at the USOR site that when applied 

in HRS Table 2-6 yields a pathway hazardous waste quantity of 100. Also, as documented in section 

4.7.2 of this HRS documentation record, a wetland is subject to Level II concentrations; therefore, a 

minimum value of 100 can be assigned for the hazardous waste quantity factor value (Ref. 1, Section 

2.4.2.2). 

Hazardous Waste Quantity Factor Value = 100 

 

4.4.3 Waste Characteristics Factor Category Value

Toxicity/Persistence Factor Value: 10,000 

Hazardous Waste Quantity Factor Value: 100 

Bioaccumulation Potential Factor Value: 50,000 

(Toxicity/Persistence Factor Value) x (Hazardous Waste Quantity Factor Value) = 1 x 106

 

(subject to a maximum of 1 x 108

) 

(Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x 

(Bioaccumulation Potential Factor Value) = 5 x 1010 

A hazardous waste quantity factor of 100 is assigned according to HRS Section 2.4.2.2. From 

Reference 2 and Table 4-12 of the HRS, manganese and mercury have a toxicity/persistence value of 

10,000 and a bioaccumulation potential factor of 50,000. The waste characteristics factor category 

value from Reference 1, Table 2-7 for a waste characteristics product of 5 x 1010 is 320. 

Hazardous Waste Quantity Assigned Value: 100 

Waste Characteristics Factor Category Value: 320
SW Pathway – Human Food Chain Threat/Waste Characteristics 

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4.5 TARGETS

Level II concentrations in the surface water pathway can be established based on sediment samples 

that meet the criteria for an observed release and the hazardous substance has a bioaccumulation 

potential factor value greater or equal to 500 (Ref. 1, Sec. 4.1.3.3). As noted in Sections 4.1.2.1.1 of 

the HRS and 4.2.1 of this HRS documentation record, an observed release of hazardous substances 

having a bioaccumulation factor value of 500 or greater is documented in Vince Bayou. A human 

food chain fishery is present in Vince Bayou at the N. Richey St. bridge within the TDL (Ref. 6, p. 

105; Ref. 17, pp. 1-2; Figure A-3). Level II concentrations of arsenic, cobalt, manganese, mercury, 

silver, and vanadium have been documented in sediments within the surface water flow path from 

PPE-06A to a distance of 2,475 feet downstream at sample location SW-01 (Ref. 34, pp. 1-2). The 

area from the farthest downstream Level II sample location (SW-01) to the 15-mile TDL is subject to 

potential contamination (refer to Figures A-4 and A-5). 

EPA Supplemental Sampling Event – March 2011 

Samples Meeting Observed Release Criteria 

Station Location 

(Sample IDs)

Distance from furthest 

upgradient PPE 

(Feet) 

(Ref. 34)

Hazardous 

Substance

Bioaccumulation 

Potential 

Factor Value

(Ref. 2)

PPE-05 

(MF3SF5//PPE-05-03-51) 290 2-Methylnaphthalene 

Naphthalene 

50,000 

50,000 

SW-10 

(MF3SE6/MF3SE7/MF3SE8) 360 

Cobalt 

Manganese 

Vanadium 

5 x 104 

5 x 108 

5 x 104

SW-09 

(MF3SF7/MF3SF6) 620 Mercury 

Silver 

5 x 108 

5,000 

SW-08 

(MF3SJ0) 895 

Barium 

Lead 

Mercury 

Silver 

5 x 106 

5 

5 x 108 

5,000 

PPE-03 

(MF3SG0/PPE-03-03-51/MF3SG1) 1,110 

Bis(2-ethylhexyl)phthalate 

Carbon Disulfide 

Silver 

50,000 

500 

5,000 

PPE-02 

(MF3SH9) 1,695 Mercury 

Silver 

5 x 108 

5,000

SW-04 

(MF3SH7/MF3SH6) 1,945 Arsenic 

Mercury 

5 x 104 

5 x 108

SW-03 

(MF3SH4/MF3SH5) 2,135 Mercury 

Silver 

5 x 108 

5,000 

PPE-01 

(MF3SH3/MF3SH2) 2,285 

Arsenic 

Mercury 

Silver 

5 x 104 

5 x 108 

5,000 

SW-02 

(MF3SG4) 2,375 Arsenic 

Mercury 

5 x 104 

5 x 108 

SW-01* 

(SED-01-03-51) 2,475 Arsenic 

Bis(2-ethylhexyl)phthalate 

5 x 104 

50,000 

*SW-01 is the farthest downstream sample location. 
SW Pathway – Human Food Chain Threat/Waste Characteristics 

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-Closed Fisheries

No fisheries within the surface water pathway have been closed due to contamination from the USOR 

site. 

-Benthic or Other Tissue 

No benthic or other tissue samples have been collected from the surface water pathway.
SW Pathway – Human Food Chain Threat/Waste Characteristics 

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4.5.1 Food Chain Individual 

Fishing is documented within the TDL off the N. Richey Street bridge (Ref. 6, p. 105; Ref. 17; 

Attachment A, Figure A-3). At this location, Vince Bayou is fished for Red Fish, Trout, Alligator Gar, 

Bass, and Catfish all of which are consumed (Ref. 3, p.1; Ref. 6, p. 105; Ref. 17, pp. 1-2). This stretch 

of river is fished for human consumption and is located within the zone of contamination, as Level II 

concentrations of arsenic, cobalt, manganese, mercury, silver, and vanadium are documented in 

discharges, surface water, and/or sediment samples located within this fishery to sample location (SW01) (see Section 4.1.2.1.1; Figure A-5 of Attachment A). 

Fishery Type of Surface Water Body Reference(s)

Vince Bayou Small to Moderate stream Ref. 31 

An observed release by chemical analysis and an observed release by direct observation are established 

to the surface water migration pathway (See Section 4.1.2.1.1 of the HRS). Since this information 

documents Level II fisheries within the target distance limit, a food chain individual value of 45 was 

assigned (Ref. 1, Section 4.1.3.3.1; Ref. 6, p. 105; Ref. 17, pp. 1-2)). 

Food Chain Individual Factor Value: 45 

4.5.2 Population 

4.5.2.1 Level I Concentrations

Level I concentrations have not been established as fish tissue samples have not been collected. 

Therefore, the Level I concentrations factor value receives an assigned value of 0.

 Level I Concentrations Factor Value: 0 

4.5.2.2 Level II Concentrations

Identity of Fishery

Annual Production 

(pounds) References

Human Food Chain 

Population Value 

Vince Bayou > 0 but unknown Ref. 1, Tables 4-13, 4-18; Ref. 17, 

pp. 1-2 

0.03 

The zone of Level II contamination in Vince Bayou extends 2,475 feet from PPE-06A (the most 

upgradient PPE) to the farthest downstream sample station, SW-01 (Section 4.1.2.1.1; Ref. 34, pp. 1-

2). Vince Bayou is fished for Red Fish, Trout, Alligator Gar, Bass, and Catfish and these fish are 

caught for human consumption (Ref. 6, p. 105; Ref. 17, pp. 1-2). This stretch of Vince Bayou is fished 

for human consumption and is located within the zone of contamination, as Level II concentrations of 

arsenic, cobalt, manganese, mercury, silver, and vanadium, are documented in discharges, surface 

water, and/or sediment samples located within this fishery (as shown in Section 4.2.1 of this report) 

(Ref. 17, pp. 1-2; Figure A-5 of Attachment A). Specific production data from the zone of 

contamination are not available; therefore, a production estimate of greater than 0 pounds per year will 

be used for the annual production rate. A human food chain population value of 0.03 is assigned from 

Table 4-18 of the HRS (Ref. 1, Table 4-18, Sec. 4.1.3.3.2.2). 
SW Pathway – Human Food Chain Threat/Waste Characteristics 

HRS Documentation Record 93 US Oil Recovery 

TXN000607093 

Level II Concentrations Factor Value: 0.03 

 

4.5.2.3 Potential Human Food Chain Contamination

Identity of 

Fishery

Annual 

Production 

(pounds)

Type of Surface 

Water Body

Average 

Annual 

Flow Reference

Population 

Value (Pi)

Dilution 

Weight (Di)

Pi x Di

Vince Bayou 

downstream of 

SW-01 

>0, but 

unknown 

Small to 

Moderate stream

10 cfs to 

100 cfs 

Ref. 1, Tables 4-

13, 4-18; Ref. 17, 

pp. 1-2; Ref. 31, 

pp. 1-3 

0.03 0.1 0.003 

Houston Ship 

Channel 

(Buffalo Bayou 

/San Jacinto 

River) 

>0, but 

unknown 

Large Stream to 

River 

>1,000 

cfs to 

10,000 

cfs 

Ref. 1, Tables 4-

13, 4-18; Ref. 36, 

p. 1; Ref. 37, pp. 

1-2 

0.03 0.001 0.00003 

Note:

cfs = cubic feet per second. 

Vince Bayou is fished for Red Fish, Trout, Alligator Gar, Bass, and Catfish and these fish are caught 

for human consumption (Ref. 6; p. 105; Ref. 17, pp. 1-2). Stream reaches within Vince Bayou and 

portions of the Houston Ship Channel within the TDL are subject to potential human food chain 

contamination, as fish are caught for human consumption (Ref. 17, pp. 1-2; Ref. 37, pp. 1-2). Data to 

estimate pounds of fish caught annually for Vince Bayou downstream of SW-01 and the Houston Ship 

Channel are not available; however, because these water bodies are fished for human consumption, the 

annual production is known to be greater than zero (Ref. 17). As such, a human food chain population 

value of 0.03 is assigned from Table 4-18 of the HRS (Ref. 1, Table 4-18). The dilution weight for 

Vince Bayou and the Houston Ship Channel (Buffalo Bayou) were based on the average annual flow 

data collected by the USGS (Ref. 31, pp. 1-3; Ref. 36, p. 1). Based on the stream flow, Vince Bayou, 

according to Table 4-13 of the HRS, is classified as a small to moderate stream and receives an 

assigned dilution weight of 0.1 (Ref. 1, Table 4-13). 

Vince Bayou - Product of Pi x Di = 0.03 x 0.1 

Product of Pi x Di: 0.003 

The Houston Ship Channel, according to Table 4-13 of the HRS, is classified as a large stream to river 

and receives an assigned dilution weight of 0.001 (Ref. 1, Table 4-13). 

Houston Ship Channel - Product of Pi x Di = 0.03 x 0.001 

Product of Pi x Di: 0.00003 

(Sum of Products of Pi x Di)/10: 0.000303 
SW Pathway – Environmental Threat/Targets 

4.6 ENVIRONMENTAL THREAT 

4.6.1 WASTE CHARACTERISTICS

Evidence of contamination associated with Sources 1 through 7 has been established based on 

chemical analyses of samples collected from these sources (refer to the Attribution section and 

Section 2.2 for each source). Arsenic, barium, cobalt, manganese, mercury, silver, and vanadium 

were detected in sediment samples collected in Vince Bayou, establishing an observed release 

(see Section 4.1.2.1.1). 

4.6.1.1 Toxicity/Persistence/Bioaccumulation 

Hazardous 

Substance

Source 

Number

Ecotoxicity

Factor 

Value

Persistence1

Factor 

Value

Ecosystem 

Bioaccumulation 

Potential Factor 

Value

Fresh2

Ecosystem 

Bioaccumulation 

Potential Factor 

Value

Salt2

Ecotoxicity/ 

Persistence/ 

Bioaccumulation 

Factor Value Reference

Arsenic 3,4,7,OR 100 1 5,000 500 5 x 105 Ref. 2, p.1

Bis(2-

ethylhexyl) 

Phthalate 

2,4,6,OR 1,000 1 50,000 5,000 5 x 107 Ref. 2, p. 

2 

Cobalt 1,4,5,6,O

R 

0 1 5,000 5,000 0 Ref. 2, p. 

3 

Lead 3,4,5,6,O

R 

1,000 1 50,000 5,000 5 x 107 Ref. 2, p. 

8 

Manganese 1,2,4,5,6,

7 

OR 

0 1 50,000 50,000 0 Ref. 2, p. 

8 

Mercury 3,6,OR 10,000 1 50,000 50,000 5 x 108 Ref. 2, p. 

8 

2-Methylnaphthalene 1,2,4,5,6, 

OR 

1000 0.4000 50,000 50,000 2 x 107 Ref. 2, p. 

9 

Naphthalene 1,2,3,4,5,

6 

OR 

1,000 0.4000 50,000 5,000 2 x 107 Ref. 2, p. 

9 

Silver 3,4,OR 10,000 1 50 50,000 5 x 108 Ref. 2, p. 

10 

Vanadium 3,4,5,6, 

7,OR 

0 1 500 500 0 Ref. 2, p. 

11 

Notes:

OR – Observed Release 

1

 The surface water category that includes rivers, oceans, coastal tidal waters, and great lakes was utilized to assign the hazardous 

substances persistence factor value (Ref. 1, Sec. 4.1.2.2.1.2). The persistence values were assigned for a river according to the 

January 2004 Superfund Chemical Data Matrix (SCDM) table (Ref. 2). 2

 Bioaccumulation factor values are assigned from the SCDM (Ref. 2), for both water body types "Fresh Water" and “Salt Water” 

in which the wetlands are located. The data that yielded the higher factor value was assigned to the Bioaccumulation Factor 

Value of the hazardous substance (Ref. 1, Sect. 4.1.3.2.1.3). 

 

Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 108

HRS Documentation Record 94 US Oil Recovery 

TXN000607093 
SW Pathway – Environmental Threat/Targets 

4.6.1.2 Hazardous Waste Quantity 

Source 

No.

Source Hazardous 

Waste Quantity 

Value

Containment

Ground Water Surface Water Gas Air Particulate

1 33.896 NE 9 NE NE 

2 1,173.333 NE 10 NE NE 

3 48.889 NE 10 NE NE 

4 2,605.912 NE 10 NE NE 

5 48.216 NE 9 NE NE 

6 67.337 NE 10 NE NE 

7 1,813.333 NE 10 NE NE 

TOTAL 5,790.916 

A hazardous waste quantity of 5,790.916 is estimated for sources at the USOR site which when 

applied in HRS Table 2-6 yields a pathway hazardous waste quantity of 100. Also, as 

documented in Sections 4.1.2.1.1 of the HRS and 4.7.2 of this HRS documentation record, a 

wetland is subject to Level II concentrations; therefore, a minimum value of 100 can be assigned 

for the hazardous waste quantity factor value (Ref. 1, Section 2.4.2.2). 

Hazardous Waste Quantity Factor Value = 100 

4.6.1.3 Waste Characteristics Factor Category Value

Ecotoxicity/Persistence Factor Value: 10,000 

Hazardous Waste Quantity Factor Value: 100 

Bioaccumulation Potential Factor Value: 50,000 

(Ecotoxicity/Persistence Factor Value) x (Hazardous Waste Quantity Factor Value) = 1 x 106

 

 (Ecotoxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x 

(Bioaccumulation Potential Factor Value) = 5 x 1010 

(Ref. 1, Section 4.1.3.2.3). 

A hazardous waste quantity factor of 100 is assigned according to HRS Section 2.4.2.2. From 

Reference 2 and Table 4-12 of the HRS, mercury has an ecotoxicity/persistence value of 10,000 

and a bioaccumulation potential factor of 50,000. The waste characteristics factor category value 

from Reference 1, Table 2-7 for a waste characteristics product of 5 x 1010 is 320. 

Hazardous Waste Quantity Assigned Value: 100 

Waste Characteristics Factor Category Value: 320 

HRS Documentation Record 95 US Oil Recovery 

TXN000607093 
SW Pathway – Environmental Threat/Targets 

HRS Documentation Record 96 US Oil Recovery 

TXN000607093 

4.7 SENSITIVE ENVIRONMENTS

4.7.1 Level I Concentrations

No Level I concentrations have been documented; therefore, Level I concentrations were not 

evaluated. 

4.7.2 Level II Concentrations

Wetlands

The area of Level II contamination extends 2,475 feet from PPE-06A in Vince Bayou to the 

farthest downstream sample location, SW-01 (Ref. 1, Section 4.1.2.1.1; Ref. 34). A total of 

approximately 1,720 linear feet of wetland frontage contiguous to Vince Bayou was determined 

to be affected by Level II concentrations (Ref. 19, pp. 1-5; Ref. 20, pp. 1-2). Since Vince Bayou 

is a surface water body with discernible flow, the wetlands on opposite banks of the stream are 

considered separate wetlands. The total length of wetlands determined in accordance with 

Sections 4.1.4.3.1.1 and 4.1.4.3.1.2 of the HRS (Ref. 1) and was calculated by adding together 

the individual lengths on each bank of the surface water body (550 feet + 840 feet+ 330 feet = 

1,720 feet) (Ref. 1, Sections 4.1.4.3.1.1 and 4.1.4.3.1.2; Ref. 20, pp. 1-2). 

According to the National Wetlands Inventory (NWI) Map of the area, updated in 2006, the 

wetlands contiguous to Vince Bayou with Level II contamination are classified as estuarine, 

intertidal, emergent wetland, persistent, irregularly flooded (E2EM1P) (Ref. 19, pp. 1-13). 

These wetlands meet the 40 CFR 230.3 definition of a wetland. 

Total Level II Wetland Frontage along Vince Bayou = 1,720 feet (0.3257 miles) 

Wetland Value (Ref. 1, Table 4-24): 25 

Level II Concentrations Factor Value: 25 
Soil Exposure Pathway – Not Scored 

HRS Documentation Record 97 US Oil Recovery 

TXN000607093 

5.0 SOIL EXPOSURE PATHWAY SCORE - NOT SCORED

The soil exposure pathway will not be scored because it is not expected to contribute significantly to 

the site score. Further, the site score already exceeds 28.50 based only on the evaluation of the surface 

water pathway. 

6.0 AIR MIGRATION PATHWAY SCORE - NOT SCORED

The air migration pathway will not be scored because it is not expected to contribute significantly to 

the site score. Further, the site score already exceeds 28.50 based only on the evaluation of the surface 

water pathway. 
ATTACHMENT A
USOR

Vince Bayou

Houston Ship Channel

USOR

MCC

SITE LOCATION

File: L:\20406_START3_R6\US_OIL_RECOVERY\GIS\FIGURE_A-1_SITE_LOCATION_MAP.mxd 4/8/2011 4:06:51 PM bondp

APR. 2011 AS SHOWN

£ 0 2,000 4,000

SCALE IN FEET

LEGEND

SITE LOCATION

TDD NO: TO-0019-11-01-01

CERCLIS: TXN000607093

SOURCE: USGS TOPOGRAPHIC QUAD MAPS

FIGURE A-1

SITE LOCATION MAP

US OIL RECOVERY

PASADENA, HARRIS COUNTY, TEXAS

DATE PROJECT NO SCALE

US EPA REGION 6

START- 3

"

TEXAS

20406.012.019.0612.01
FIGURE A-2A

US OIL RECOVERY PROPERTY LAYOUT MAP

400 N. RICHEY STREET PROPERTY

US OIL RECOVERY

PASADENA, HARRIS COUNTY, TEXAS

20406.012.019.0612.01 AS SHOWN

TDD NO: TO-0019-11-01-01

CERCLIS: TXN000607093

SOURCE: HARRIS COUNTY APPRAISAL DISTRICT

FILE: C:\Users\bondp\Desktop\US_OIL_RECOVERY\GIS\FIGURE_A-2A_PROPERTY_LAYOUT_MAP_PORTRAIT.mxd 1:42:58 PM 5/26/2011 bondp

MAY, 2011

"

TEXAS

Parking

Parking

Guard Shack

Entrance Gate

Vince Bayou

Tank Farm

Secondary 

Containment

Truck Bay Sumps

(also known as 

Sumps 34-36)

N. Richey Street

ASTs

Bio Reactors

(Aeration Basin)

Containment

Pond

Rolloff Boxes

Rolloff

Boxes

Rolloff

Boxes

Rolloff Boxes

Rolloff Boxes

Rolloff Boxes

Main

Office

Warehouse

Container Storage

Area

Machine Shop

Lab

DATE PROJECT NO SCALE

US EPA REGION 6

START-3 LEGEND

CULVERT

SOURCE 1 OVERLAND FLOW PATH

SOURCE 2 OVERLAND FLOW PATH

SOURCE 3 OVERLAND FLOW PATH

SOURCE 5 OVERLAND FLOW PATH

SOURCE 6 OVERLAND FLOW PATH

SOURCE 7 OVERLAND FLOW PATH

SOURCE 8 OVERLAND FLOW PATH

FENCED PROPERTY BOUNDARY £

0 80 160

SCALE IN FEET
FIGURE A-2B

MCC RECYCLING PROPERTY LAYOUT MAP

200 N. RICHEY STREET PROPERTY

US OIL RECOVERY

PASADENA, HARRIS COUNTY, TEXAS

20406.012.019.0612.01 AS SHOWN

TDD NO: TO-0019-11-01-01

CERCLIS: TXN000607093

SOURCE: HARRIS COUNTY APPRAISAL DISTRICT

FILE: C:\Users\bondp\Desktop\US_OIL_RECOVERY\GIS\FIGURE_A-2B_PROPERTY_LAYOUT_MAP_PORTRAIT.mxd 1:51:27 PM 5/26/2011 bondp

MAY, 2011

"

TEXAS

Oxygen

Digester 2

Oxygen

Digester 1

Lift

Station 2

Lift

Station 3

Headworks

Lift

Station 1

Sand Filter

Belt

Filter Press

Building

Chlorine

Contact

Tank

Clarifier #2 Clarifier #1

Gravity

Thickener

Aerobic

Digester

Primary

Clarifier

High Rate

Trickling

Filter

N. Richey St

W. Richey St

Pump

Control

Room

Oxygen Activated

Sludge Tank

(Aeration Basin)

Aeration Basin

(Final Clarifier)

Vince Bayou

DATE PROJECT NO SCALE

US EPA REGION 6

Legend START-3

APPROXIMATE PIPELINE

LOCATION

SOURCE 4 OVERLAND FLOW PATH

FENCED PROPERTY BOUNDARY £

0 90 180

SCALE IN FEET
 

 

 

 

 

 

 

 

 

 

 

 

PPE-01 

( !

TEXAS 

" 

PPE-02 

( !

Vince Bayou

( !

Little Vince Bayou 

PPE-02A 

LEGEND 

( 

!( PROBABLE POINT OF ENTRY 

OVERLAND FLOW DIRECTION 

SITE BOUNDARY 

USOR 

( !

PPE-03 

( !

PPE-04 £ 

( !

( !

MCC

PPE-06 

PPE-05 

TDD NO:

CERCL 

TO-0019-11-01-01

IS:

SOURCE 

TXN000607093

: HARRIS COUNTY APPRAISAL DISTRICT

AERIAL: BING IMAGE SERVICE 

0 240 480 

SCALE IN FEET 

US EPA REGI

START 

ON 6

- 3 

PPE-06A 

( !

MCC 

FIGURE A-3

SURFACE WATER PATHWAY MAP

US OIL RECOVERY

PASADENA, HARRIS COUNTY, TEXAS 

DATE

MAR 2011 

PROJECT NO

20406.012.019.0612.01 

SCALE

AS SHOWN 

File: L:\20406_START3_R6\US_OIL_RECOVERY\GIS\FIGURE_A-3_SURFACE_WATER_PATHWAY_MAP.mxd 4/8/2011 4:12:39 PM bondp 
(!

(!

HOUSTON SHIP CHANNEL

VINCE BAYOU

DATE PROJECT NO SCALE

File: L:\20406_START3_R6\US_OIL_RECOVERY\GIS\FIGURE_A-4_15_MILE_TARGET_DISTANCE_LIMIT_MAP.mxd 4/8/2011 4:16:16 PM bondp

APR. 2011 20406.012.019.0612.01 AS SHOWN

US EPA REGION 6

START- 3

LEGEND

(! PROBABLE POINT OF ENTRY 

SAMPLE

FLOW DIRECTION

SITE BOUNDARY

TDD NO: TO-0019-11-01-01

CERCLIS: TXN000607093

SOURCE: HARRIS COUNTY APPRAISAL DISTRICT

"

TEXAS

£

FIGURE A-4

15 MILE TARGET DISTANCE LIMIT MAP

US OIL RECOVERY

PASADENA, HARRIS COUNTY, TEXAS

0 1 2

Miles

15 Mile Target

Distance Limit

PPE-06A (Furthest Upstream PPE)

PPE-1 (Furthest Downstream PPE)

Begin 0.36 mile in Vince Bayou

Begin 10.3 miles

Houston Ship Channel

Burnet Bay

Crystal Bay

Scott Bay

Mitchell Bay

Upper San

Jacinto Bay

Begin 4.34 miles San

Jacinto River System

(applied as an arc)
(!

(!

(!

(!

(!

(!

(!

")

")

#*

#*

#*

")

")

#*

#*

#*

#*

#*

#*

")

")

#*

")")

")

")

")

N. Richey St

Vince Bayou

W. Richey St

Crown St.

Little Vince Bayou

PPE-06

PPE-05

PPE-04

PPE-03

PPE-01

PPE-02

SW-11

(PPE-06A)

SW-10

SW-09

SW-01

SW-02

SW-03

SW-04

SW-08

WW-02 NTF-01

NTF-02

D0745

D0761

T0126

T0212

R0132

WW-01

SS-03

SS-02

SS-01

SS-07

SS-06

SS-05

SS-04

BG-02

BG-01

DATE PROJECT NO SCALE

File: L:\20406_START3_R6\US_OIL_RECOVERY\GIS\FIGURE_A-5_SAMPLE_LOCATION_MAP.mxd 8/16/2011 11:09:18 AM bondp

AUG 2011 20406.012.019.0612.01 AS SHOWN

US EPA REGION 6

START- 3

LEGEND

#* LEVEL II SEDIMENT SAMPLE

") LEVEL II SURFACE WATER AND SEDIMENT SAMPLE

")

SOURCE CLASSIFICATION SAMPLE

") BACKGROUND SAMPLE

(! SURFACE SOIL SAMPLE FROM

OVERLAND FLOW PATH

FLOW DIRECTION

SITE BOUNDARY

LEVEL II WETLANDS

TDD NO: TO-0019-11-01-01

CERCLIS: TXN000607093

SOURCE: ESRI World Imagery Service

"

TEXAS

£

FIGURE A-5

SAMPLE LOCATION MAP

US OIL RECOVERY

PASADENA, HARRIS COUNTY, TEXAS

0 250 500

SCALE IN FEET

LEVEL II DOCUMENTED

FISHING AREA (HUMAN FOOD CHAIN

ZONE OF CONTAMINATION)

ZONE OF CONTAMINATION

FOR ENVIRONMENTAL THREATS