### HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD

- REVIEW COVER SHEET

Name of Site: US Oil Recovery

EPA ID No.: TX N000607093

Contact Persons

Site Investigation: Brenda Nixon Cook, NPL Coordin (Name) ator, EPA Reg.6 (214) 665-7436 (Telephone)

Documentation Record: Brenda Nixon Cook, NPL Coordin (Name) ator, EPA Reg.6 (214) 665-7436 (Telephone)

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 migrati on 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

wou ld 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, t he Drinking W ater 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 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 Revised: September 2012

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 (19 95 ) (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). 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

*The street address, coordinates, and contaminant locations presented in this HRS documentation record identify the general a rea in which the site is located. They represent one or more locations EPA considers to be part of the site based on the screening inform ation EPA used to evaluate the site for NPL listing. EPA lists national priorities among the known "releases or threatened release s" 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 sub sequent listing of a release merely represent the initial determination that a certain area may need to be addressed under CERCLA. Accordingly, EP A 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.

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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 040001 in 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

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XN000607093 

### 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. Updated March 31, 2012. 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 ® 

### ). 2010. Project Note to File. Measurement of the Latitude and Longitude coordinates at US Oil Recovery . 7 February 2011 . Pages: 2.

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

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

6. TCEQ . 20 10. 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. Res ource Conservation Recovery Act Compliance Evaluation Inspection. US Oil Recovery L.P. Pasadena, Texas. TXR000051540. November and December 2009. Pages: 17.

10. WES T ON. 2010. Summary of Container Information and Hazardous Categorization Sheets

. US Oi l 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. 201 1 . Pr oject 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

### 2007. Pages: 5.

15. WESTON. 201 1 . 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/Pas adena_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 L aboratories. 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 R epo rt. 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 Incid ent 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,

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

30. EPA. Organic Data Assessment. SDG F3SD0 , Case 41079 (e xcerpts ). 23 March 2011. Pages: 238.

31. USGS. Water Data Report. 2010. 08075730 Vince Bayou at Pasadena, T exas . 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, T exas

. 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/in

the- news/clean

- water/clean

- water/en vironmental-group- takes

- aim

- at

- polluted -ship- channel. Accessed 29 March 2011 . Pages: 2.

38. EPA. Inorganic Data Assessment. SDG MF3SH8 , Case 41079 (e xcerpts ). 18 March 2011. Pages: 85.

39. EPA. Organic Data Assessment. SDG F3S G 8, Case 41079 (excerpts). 29 March 2011. Pages: 202.

40. EPA. Inorganic Data Assessment. SDG MF 3SD1 , Case 41079 (excerpts). 1 April 2011. Pages: 153.

41. EPA. Inorganic Data Assessment. SDG MF 3SG7 , 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). 200 1. 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 4 00 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 t he properties (identified as USOR on Figure A

- 1) consists of a centralized waste treatment plant that receives and treats oily waste

, sludge

, and organic chemical

bearing 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 fa cility is an abandoned used oil processor and wastewater treatment facility

. The USOR waste
treatment operations at 400 N. Richey Street began in 200 2 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 , p p. 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 pres s operation. Wastewater with less than five percent solids and decant from the other wastewater pits were piped into treatment tanks ( Ref. 5 , p p. 13 , 305 ). After treatment by USOR

, the effluent (an oily water mixture) wa s piped via pipeline to the industri al 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 consist s 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 seco nd 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 lab oratory, machine shop, container storage area, and parts warehouse. A t ank 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 th e 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 station s for transferring wastewater from the west plant to the east plant. The east plant has a small gravity thick ener 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 slu dge tank . The remains of a sand filter are next to the oxygen digesters and oxygen activated sludge tank . Two final clarifiers (C larifier #1 and C larifier #2) are behind the oxygen activated sludge tank ( Ref. 5 , p . 311; Ref. 6 , p p . 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 o verland 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; s urface 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 contaminatio n threatens a nearby human food chain fishery and sensitive environments.

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:

• December 2003 and January 2004 - T he 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).

• 24 February 2004

- the TCEQ issued a N otice of Violation to USOR. Some of the issues noted included: processing grease trap and grit waste without authorization; emission of strong foul odor; processing in dustrial non-hazardous liquid waste in its WWTP , and t ransportin g

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### treated wastewater effluent to the Gulf Coast Waste D isposal Authority for disposal ( Ref. 47, p. 6 ).

7 October 2005 - T he TCEQ Region 12 Waste Program conducted a sampling i nvestigation 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 manho le. The soil sample results showed concentrations of arsenic, lead, and mercury exceeding Texas Risk Reduction Program ( TRRP ) Tier 1 p rotective concentration l evels ( PCLs ) for soil at commercial/industrial sites near the manhole on the southeast side of th e site and at the storm water outfall near the front gate (Ref. 5, p. 477)

• 23 February 2 006

- 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/process ing 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 - T he 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 fee t 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 b ioreactors 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 cas e of the spill s discharg ing 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 Recy cling (Ref. 9, p. 4). A n 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 s ite 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, p p . 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 t emporary i njunction issued by Harr is County. The injunction required USOR to cease the intake of wastewater unt il 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 loca ted 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 tank s or basin s 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, h ydrocarbon 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 date d 27 August 2009 concerning the odor emissions contain ing benzene and acetone. The notice also addresse d the leaks from the trickling filter and non

compliance issues with the injunction ( Ref. 12, p. 7).

• September through December 2009 - T he U.S. Coast Guard issued an Administrative Order to USOR to remove the waste from the bioreactors due to the inadequate structur al 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 b ox 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 release s 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 usi ng 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 - T he 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: l eaking containers; c ontainers stored in an unsafe manner; u niversal waste not stored in separate double rows of containers; f ail ure to ensure all containers of hazardous waste were closed or covered; f ailure to ensure waste was stored in leak free containers; f ailure to obtain a RCRA permit to store hazardous waste in the aeration basin and in the container storage area; and, f ail ure to prevent the discharge or imminent threat of discharge of industrial solid waste or municipal hazar dous 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 d raining off

- site to Vince Bayou (Ref. 5, pp. 18, 19). Other violations observed included fail ure to notify TCEQ of the tra nsfer of hazardous waste sludge from bioreactors (C

- 63 and C -64 ) to on

- site roll

- off boxes and fail ure 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 overflow ing with an oily sheen disc harg ing 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 labe ls (Ref. 5, pp. 18, 288) . EPA took samples of the drum contents labeled hazardous waste and results confirm ed the drums contain ed 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 exce eding the regulatory limit for benzene and m ercury (Ref. 5, p. 289)

. As a result of the inspection, EPA inspectors determined that USOR had

HRS Documentation Record US Oil Recovery 

### 12 T XN000607093

### received numer ous shipments of hazardous waste that USOR was not authorized to receive and/or treat. Shipment of hazardous waste include d 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 tha t these containers were leaking ( Ref. 48, p. 2 ). Also during th is 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. W astewater 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 a cids 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 ( Re f. 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 contain ing oily waste and its walls were dete riorating ( 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 Stree t 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 ).

HRS Documentation Record US Oil Recovery 

### 13 T XN000607093

### o Li quid from the chlorine contact chamber was surfacing from cracks in a concrete road near the northwest corner of the ch lorine 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 secu red 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 in side the warehouse. Placards and painting markings were placed at each contain ment area according to hazardous characterization. Approximately 392,000 gallons of non

- hazardous material w as transported off

- site for disposal ( Ref. 5 , pp. 19- 20, 74-75 ; Ref . 7, p. 19)

.

• 4 November 2010 - H CPHES 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 p arking lot. Approximately 410 ,000 gallons of non

hazardous 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 lea king 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 dispos al as non

- hazardous waste (Ref. 5, p p. 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 off

site. 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 de mobilized 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 s ampling at the USOR site in March 2011 . During this time

, the following samples were collected: 2 1 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 (Re f. 44, p. 4). The samples were analyzed for Target Compound List (TCL)

HRS Documentation Record US Oil Recovery 

### 14 T XN000607093

### volatile organic compounds (VOCs), TCL semivolatile organic compounds (SVOCs) by the Contract Laboratory Program (CLP) Statement of Work (SOW) for Multi

- Media, Multi

Concentration 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 201 1, 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).

HRS Documentation Record US Oil Recovery 

### 15 T XN000607093

### WORKSHEET FOR COMPUTING HRS SITE SCORE

S S 2



### 1. Ground Water Migration Pathway Score (S gw 

### ) 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 (S sw 

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

3. Soil Exposure Pathway Score (S s 

### ) NS NS (from Table 5 -1, line 22)

4. Air Migra tion Pathway Score (S a 

### ) NS NS (from Table 6 -1, line 12)

5. Total of S gw 2 

### + S sw 2 

### + S s 2 

### + S a 2



### ---- 10,000

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

Notes :

S Score S 2 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.

HRS Documentation Record US Oil Recovery 

### 16 T XN000607093DRINKING WATER THREAT

- Not Scored (NS)



### Factor Categories and Factors Maximum Value Value Assigned

Likelihood of Release

1. 2.

3.

4.

5. Observed Release Potential to Release by Overland Flow: 2a. Containment 2b. Runoff 2c. Distance to Surface Water 2d. Potential to Release by Overland Flow (lines 2a[2b + 2c]) Potential to Release by Flood: 3a. Containment (Flood) 3b. Flood Frequency 3c. Potential to Release Flood (lines 3a x 3b) Potential to Release (lines 2d + 3c, subject to a maximum of 500) Likelihood of Release (higher of lines 1 and 4) 550

10 25 25

500

10 50

500

500 550 550

NS NS NS

NS

NS NS

NS

NS 550

Waste Characteristics

6. 7. 8. Toxicity/Persis tence Hazardous Waste Quantity Waste Characteristics (Toxicity/Persistence x Hazardous Waste Q uantity, then assign a value from Table 2

- 7) Targets a

a

100 NS NS

NS

9. Nearest Intake 10. Population 10a. Level I Concentrations 10b. Level II Concentrations 10c. Potential Contamination 10d. Population (lines 10a + 10b + 10c) 11. Resources 12. Targets (lines 9 + 10d +11) Drinking Water Threat Score 50

b b b

b 5 b NS

NS NS NS

NS NS NS

13. Drinking Water Threat Score [(lines 5 x 8 x 12)/82,500 subject to a maximum of 100] 100 NS

HRS Documentation Record US Oil Recovery 

### 17 T XN000607093HUMAN 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 5x10 8
16. Hazardous Waste Quantity a 100 17. Waste Characteristics (Toxicity/Persistence/Bioaccumulation x Hazardous Waste Q uantity, 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 0.00 0 303 19d. Population (lines 19a + 19b + 19c) b 0.0 30 303 20. Targets (lines 18 + 19d) b 45.03 0 303

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

HRS Documentation Record US Oil Recovery 

### 18 T XN000607093ENVIRONMENTAL 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 5x10 8
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

SURFAC E 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

HRS Documentation Record US Oil Recovery 

### 19 T XN000607093Source Characterization

- Source 1



### 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 on

site 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 th e 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; in adequate 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 a ctivities 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, s econdary 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 depicte d on Attachment A, Figure A- 2A.

Source Containment

Release To Surface Water

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 di srepair (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 , p p. 18, 75, 288-289 ; Ref. 8, pp. 8, 110

- 119, 123

- 138, 140 -142)

. Since the EPA response

HRS Documentation Record US Oil Recovery 

### 20 T XN000607093Source Characterization

- Source 1



### 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 (D 0745 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 , p p . 1 3 , 62, 69, 75 ). Drums D 0745 and D 0761 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).

A nalytical evidence of the contamination in waste source samples associated with the two d rums located on the USOR site is summarized below

.

Hazardous Substance Evidence References Sample ID Concentration (mg/L) Reporting Limit 1 (mg/L)

EPA Supplemental Sampling Activities – March 2011

Acetone D0745

- 00

- 81 0.0892 0.010 Ref. 24, p p

. 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, p p

. 173

, 326; Ref. 28, p. 73

Cobalt D0745

- 00

- 81 7.83 2 Ref. 24, p p

. 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, p p . 17 7

, 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

HRS Documentation Record US Oil Recovery 

### 21 T XN000607093Source Characterization

- Source 1

Hazardous Substance Evidence References Sample ID Concentration (mg/L) Reporting Limit 1 (mg/L)

Phenanthrene 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 Quant itation 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 avai lable 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 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 e stimated 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 co ntents 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).

Waste Stream 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

HRS Documentation Record US Oil Recovery 

### 22 T XN000607093Source Characterization

- Source 1

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

Subt otal 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,

Subt otal 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,

Subt otal Volume of Gel 769

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

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

Subt otal Volume of Liquid/Solids 100

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

Flammable Solid 11 00 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

Subt otal 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 ,0 00 Hazardous Waste stream Quantity = 33.896

HRS Documentation Record US Oil Recovery 

### 23 T XN000607093Source Characterization

- Source 1



### 2.4.2.1.3 Tier C: Volume - Not Evaluated (NE)

T ier 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)

T ier 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 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).

Tier Eva luated Source 1 Values
A Not Evaluated
B 33.896
C Not Evaluated
D Not Evaluated



### Source Hazardous Waste Quantity Value: 33.896

HRS Documentation Record US Oil Recovery 

### 24 T XN000607093Source Characterization

- Source 2



### 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 a s the a eration b asin 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 c oncrete 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, stabilize d 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.

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.

• In December 2007, TCEQ investigators found that an unauthorized discharge of wastewater onto the ground was occurring fr om cracks in the west wall of the aeration basi n (also known as bioreactors) ( Ref. 5 , pp. 17, 338 ).

• 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

HRS Documentation Record US Oil Recovery 

### 25 T XN000607093Source Characterization

- Source 2



### 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 conta inment value of 10 was selected for Source 2 based on the evidence cited above of hazardous substance migration from th e 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 PC Ls (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 ISM 05.3 by the EPA Region 6 Environmental Services Branch Laboratory (Ref. 24, p p

. 165-170, 325).

A nalytical 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 s ite is summarized in the following table

.

Hazardous Substance Evidence References Sample
ID Concentration RL 1 Units

EPA Supplemental Sampling Activities – March 2011

Acetone WW

- 02

- 00

- 11

- 20110303 0.774 0. 10 mg/L Ref. 24, pp. 1 65

, 325 ; Ref. 28, p. 73 Methylene chloride WW

- 02

- 00

- 11

- 20110303 0.0260 0.002 mg/L Ref. 24, pp. 1 65

, 325 ; Ref. 28, p. 73

Methyl acetate WW

- 02

- 00

- 11

- 20110303 0.0159 0.002 mg/L Ref. 24, pp. 1 65

, 325 ; Ref. 28, p. 73 Methy tert

- butyl ether WW

- 02

- 00

- 11

- 20110303 0.0074 0. 002 mg/L Ref. 24, pp. 1 65

, 325 ; Ref. 28, p. 73

2

- Butanone WW

- 02

- 00

- 11

- 20110303 0.519 0. 05 mg/L Ref. 24, pp. 1 65

, 325 ; Ref. 28, p. 73
1,2

- Dichloroethane WW

- 02

- 00

- 11

- 20110303 0.0038 0.002 mg/L Ref. 24, pp. 1 65

, 325 ; Ref. 28, p. 73

Benzene WW

- 02

- 00

- 11

- 20110303 0.0316 0.002 mg/L Ref. 24, pp. 1 65

, 325 ; Ref. 28, p. 73

Trichloroethene WW

- 02

- 00

- 11

- 20110303 0.0033 0.002 mg/L Ref. 24, pp. 1 65

, 325 ; Ref. 28, p. 73

4

- Methyl

- 2

- pentanone WW

- 02

- 00

- 11

- 20110303 0.0112 0.005 mg/L Ref. 24, pp. 1 66

, 325 ; Ref. 28, p. 73

Toluene WW

- 02

- 00

- 11

- 20110303 0.0104 0.002 mg/L Ref. 24, pp. 1 66

, 325 ; Ref. 28, p. 73

2

- Hexanone WW

- 02

- 00

- 11

- 20110303 0.0094 0.005 mg/L Ref. 24, pp. 1 66

, 325 ; Ref. 28, p. 73 Ethylbenzene WW

- 02

- 00

- 11

- 20110303 0.0035 0.002 mg/L Ref. 24, pp. 1 66

, 325 ; Ref. 28, p. 73

meta

- /para

- Xylene WW

- 02

- 00

- 11

- 20110303 0.0138 0.004 mg/L Ref. 24, pp. 1 66

, 325 ; Ref. 28, p. 73

ortho

- Xylene WW

- 02

- 00

- 11

- 20110303 0.0056 0.002 mg/L Ref. 24, pp. 1 66

, 325 ; Ref. 28, p. 73

HRS Documentation Record US Oil Recovery 

### 26 T XN000607093Source Characterization

- Source 2

Hazardous Substance Evidence References Sample
ID Concentration RL 1 Units

Acetophenone WW

- 02

- 00

- 11

- 20110303 0.120 0.10 mg/L Ref. 24, pp. 1 67

, 325 ; Ref. 28, p. 73

Benzoic acid WW

- 02

- 00

- 11

- 20110303 4.71 J 2.0 mg/L Ref. 24, pp. 1 67

, 325 ; Ref. 28, p. 73 Bis(2

- ethylhexyl)phthalate WW

- 02

- 00

- 11

- 20110303 0.506 0.10 mg/L Ref. 24, pp. 1 67

, 325 ; Ref. 28, p. 73

Di

- n

- butyl phthalate WW

- 02

- 00

- 11

- 20110303 0.497 0.10 mg/L Ref. 24, pp. 1 68

, 325 ; Ref. 28, p. 73

2

- Methylnaphthalene WW

- 02

- 00

- 11

- 20110303 0.0618 0.04 mg/L Ref. 24, pp. 1 68

, 325 ; Ref. 28, p. 73

3&/or4

- M e thylphenol WW

- 02

- 00

- 11

- 20110303 0.338 0.10 mg/L Ref. 24, pp. 1 68

, 325 ; Ref. 28, p. 73 Naphthalene WW

- 02

- 00

- 11

- 20110303 0.226 0.04 mg/L Ref. 24, pp. 1 68

, 325 ; Ref. 28, p. 73

Phanathrene WW

- 02

- 00

- 11

- 20110303 0.187 0.04 mg/L Ref. 24, pp. 1 69

, 325 ; Ref. 28, p. 73

Phenol WW

- 02

- 00

- 11

- 20110303 5.61 1.0 mg/L Ref. 24, pp. 1 69

, 325 ; Ref. 28, p. 73

Barium WW

- 02

- 00

- 11

- 20110303 0.110 0.10 mg/L Ref. 24, pp. 1 70

, 325 ; Ref. 28, p. 73 Manganese WW

- 02

- 00

- 11

- 20110303 0.49 0.050 mg/L Ref. 24, pp. 1 70

, 325 ; Ref. 28, p. 73

Nickel WW

- 02

- 00

- 11

- 20110303 0.317 0.20 mg/L Ref. 24, pp. 1 70

, 325 ; Ref. 28, p. 73

Zinc WW

- 02

- 00

- 11

- 20110303 1.9 0.20 mg/L Ref. 24, pp. 1 70

, 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 dete rmine 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 Tier C: Volume

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

m easurements of the biore actor. Using this methodology, t he 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 )

.

HRS Documentation Record US Oil Recovery 

### 27 T XN000607093Source Characterization

- Source 2



### The Tier C equation for assigning a value for volum es 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 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 quant ity (Tier B), v olume (T ier C), and a rea (Tier D) should be assigned as the source hazardous waste quantity value (Ref. 1, Section 2.4.2.1.5).

Tier Evaluated Source 2 Values
A Not Evaluated
B Not Evaluated
C 1,173.333
D 0



### Source Hazardous Waste Quantity Value: 1,173.333

HRS Documentation Record US Oil Recovery 

### 28 T XN000607093Source Characterization

- Source 3



### SOURCE DESCRIPTION

2.2 Source Characterization

Source Description: Source 3 - Truck Bays used as Sumps

The truck bay sumps (also known as B ays 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 ar e shown on Attachment A, Figure A-2A.

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 S umps 34 through 36) had become compromised due to heavy rains and the contents were overflow ing 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 Subs tances

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

HRS Documentation Record US Oil Recovery 

### 29 T XN000607093Notes: (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 T he 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 a n 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 inten ded 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



### 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 Rec overy 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
ID Concentration MQL 1 Units References

Benzene WP 0 3

- 71

- 10111 6 0.273 3 0. 25 mg/L Ref. 45, pp. 18, 24 ; Ref.49, pp. 1,8 Methyl ethyl ketone WP 0 3

- 71

- 10111 6 0.320 JQ 3 0.50 mg/L Ref. 45, pp. 18, 24 ; Ref.49, pp. 1,8

2

- Methylphenol WP 0 3

- 71

- 10111 6 0.0353 JQ 3 0.050 mg/L Ref. 45, pp. 19, 24 ; Ref.49, pp. 9, 16

3&4

- Methylphenol WP 0 3

- 71

- 10111 6 0.0797 3 0.050 mg/L Ref. 45, pp. 19, 24 ; Ref.49, pp. 9, 16

Barium WP 03- 71

- 10111 6 0.21 JQK 3 5.0 mg/L Ref. 45, pp. 20, 24; Ref.49, pp. 17, 2 7

Chromium WP 0 3

- 71

- 10111 6 0.021 JQK 3 0.0 50 mg/L Ref. 45, pp. 20, 24 ; Ref.49, pp. 17, 2 7

Arsenic WP 0 3

- 71

- 10111 6 5.5 0.68 mg/kg Ref. 45, pp. 22, 24 ; Ref.49, pp. 17, 24

Barium WP 0 3

- 71

- 10111 6 518 14 mg/kg Ref. 45, pp. 22, 24 ; Ref.49, pp. 17, 24

Cadmium WP 0 3

- 71

- 10111 6 0.50 0.34 mg/kg Ref. 45, pp. 22, 24 ; Ref.49, pp. 17, 24

Chromium WP 0 3

- 71

- 10111 6 40.9 0.68 mg/kg Ref. 45, pp. 22, 24 ; Ref.49, pp. 17, 24

Lead WP 0 3

- 71

- 10111 6 45.3 0.68 mg/kg Ref. 45, pp. 22, 24 ; Ref.49, pp. 17, 24 Mercury WP 0 3

- 71

- 10111 6 9.5 0.96 mg/kg Ref. 45, pp. 22, 24 ; Ref.49, pp. 17, 24

Selenium WP 03- 71

- 10111 6 0.96 0.68 mg/kg Ref. 45, pp. 22, 24 ; Ref.49, pp. 17, 24

Silver WP 0 3

- 71

- 10111 6 0.60 JQ 0.68 mg/kg Ref. 45, pp. 22, 24 ; Ref.49, pp. 17, 24

HRS Documentation Record 

### 30 US Oil Recovery T XN000607093Source Characterization

- Source 3



### 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 d etermine 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 d etermine 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 e valuated (Ref. 1, Section 2.4.2.1.4).

Area Assigned Value = 0

2.4.2.1.5 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

HRS Documentation Record US Oil Recovery 

### 31 T XN000607093Source Characterization

- Source 3



### 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

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### 32 T XN000607093Source Characterization

- Source 4



### SOURCE DESCRIPTION

2.2 Source Characterization

Source Description: Source 4 – MCC Surface Im poundments

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 separa tor). 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 W WTP 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 wastewate r 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 (open

top concrete structures), all received wastewater from the USOR property, have similar containment, affect same targets, contain simi lar 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.

Source Containment

Release To Surface Water

The contents of each reservoir are exposed to precipitation and surface water (throug h flooding). Agencies including EPA, TCEQ, and HCPHES have documented multiple spills from the wastewater

HRS Documentation Record US Oil Recovery 

### 33 T XN000607093Source Characterization

- Source 4



### 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 n orthwest 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 w ater 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 on e 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

HRS Documentation Record US Oil Recovery 

### 34 T XN000607093Source Characterization

- Source 4



### metals and mercury by CLP ISM0 5.3 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 s urface 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 References Sample
ID Concentration RL/ MQL 1 Units

EPA Emergency Response Activities – July 2010 2

Acetone MCC

- WW03

- 11

- 100712 0.777 0. 0 50 mg/L Ref. 22, pp. 7, 56; Ref. 23, p p

. 1, 6

Carbon disulfide MCC

- WW03

- 11

- 100712 0.0176 0. 00 20 mg/L Ref. 22, pp. 7, 56; Ref. 23, p p

. 1, 6

Ethylbenzene MCC

- WW03

- 11

- 100712 0.00098 JQ 0. 0020 mg/L Ref. 22, pp. 7, 56; Ref. 23, p p

. 1, 6

4

- Methyl

- 2

- pentanone MCC

- WW03

- 11

- 100712 0.0509 JK 0. 0 10 mg/L Ref. 22, pp. 7, 56; Ref. 23, p p

. 1, 6

Methyl ethyl ketone MCC

- WW03

- 11

- 100712 0.186 JK 0. 0 10 mg/L Ref. 22, pp. 7, 56; Ref. 23, p p

. 1, 6

Toluene MCC

- WW03

- 11

- 100712 0.0042 0. 00 20 mg/L Ref. 22, pp. 7, 56; Ref. 23, p p

. 1, 6 Xylene (total) MCC

- WW03

- 11

- 100712 0.0023 JQ 0.00 60 mg/L Ref. 22, pp. 8, 56; Ref. 23, p p

. 1, 7

Benzoic acid MCC

- WW03

- 11

- 100712 0.586 0. 0 58 mg/L Ref. 22, pp. 9, 56; Ref. 23, p p

. 1, 27

2

- Methylphenol MCC

- WW03

- 11

- 100712 0.0618 0. 029 mg/L Ref. 22, pp. 9, 56; Ref. 23, p p

. 1, 27

3&4

- Methylphenol MCC

- WW03

- 11

- 100712 0.519 0. 0 29 mg/L Ref. 22, pp. 9, 56; Ref. 23, p p

. 1, 27

Phenol MCC

- WW03

- 11

- 100712 0.499 0. 0 29 mg/L Ref. 22, pp. 9, 56; Ref. 23, p p

. 1, 27 bis(2

- Ethylhexyl)phthalate MCC

- WW03

- 11

- 100712 0.0107 JQ 0. 0 29 mg/L Ref. 22, pp. 10 , 56; Ref. 23, p p

. 1, 28 Antimony MCC

- WW03

- 11

- 100712 0.0027 JQ 0. 00 5 0 mg/L Ref. 22, pp. 1 2

, 56; Ref. 23, p p

. 1, 56

Arsenic MCC

- WW03

- 11

- 100712 0.0065 0. 00 5 0 mg/L Ref. 22, pp. 1 2

, 56; Ref. 23, p p

. 1, 56

Barium MCC

- WW03

- 11

- 100712 0.0102 JQ 0. 20 mg/L Ref. 22, pp. 1 2

, 56; Ref. 23, p p

. 1, 56

Chromium MCC

- WW03

- 11

- 100712 0.0026 JQ 0. 0 10 mg/L Ref. 22, pp. 1 2

, 56; Ref. 23, p p

. 1, 56

Cobalt MCC

- WW03

- 11

- 100712 0.0036 0. 0 50 mg/L Ref. 22, pp. 1 2

, 56; Ref. 23, p p

. 1, 56

Lead MCC

- WW03

- 11

- 100712 0.0049 0.00 30 mg/L Ref. 22, pp. 1 2, 56; Ref. 23, p p

. 1, 56 Manganese MCC

- WW03

- 11

- 100712 0.0225 0. 0 15 mg/L Ref. 22, pp. 1 2

, 56; Ref. 23, p p

. 1, 56

Nickel MCC

- WW03

- 11

- 100712 0.0675 0. 0 40 mg/L Ref. 22, pp. 1 2

, 56; Ref. 23, p p

. 1, 56

Selenium MCC

- WW03

- 11

- 100712 0.0012 JQK 0.00 50 mg/L Ref. 22, pp. 1 2, 56; Ref. 23, p p

. 1, 56

Vanadium MCC

- WW03

- 11

- 100712 0.0018 JQ 0. 0 50 mg/L Ref. 22, pp. 1 2

, 56; Ref. 23, p p

. 1, 56

Zinc MCC

- WW03

- 11

- 100712 0.055 JK 0. 0 20 mg/L Ref. 22, pp. 1 2

, 56; Ref. 23, p p

. 1, 56

Acetone MCC

- WW04

- 11

- 100712 0.382 0. 0 50 mg/L Ref. 22, pp 13, 56; Ref. 23, p p

. 1, 8

Carbon disulfide MCC

- WW04

- 11

- 100712 0.0091 0. 00 20 mg/L Ref. 22, pp 13, 56; Ref. 23, p p

. 1, 8

4

- Methyl

- 2

- pentanone MCC

- WW04

- 11

- 100712 0.0606 JK 0. 0 10 mg/L Ref. 22, pp 13, 56; Ref. 23, p p

. 1, 8

Methyl ethyl ketone MCC

- WW04

- 11

- 100712 0.160 JK 0. 0 10 mg/L Ref. 22, pp 13, 56; Ref. 23, p p

. 1, 8

Toluene MCC

- WW04

- 11

- 100712 0.0015 JQ 0. 00 20 mg/L Ref. 22, pp 13, 56; Ref. 23, p p

. 1, 8

Benzoic acid MCC

- WW04

- 11

- 100712 0.173 0.0 55 mg/L Ref. 22, pp. 15, 56; Ref. 23, p p. 1, 30

2

- Methylphenol MCC

- WW04

- 11

- 100712 0.0236 JQ 0. 0 27 mg/L Ref. 22, pp. 15, 56; Ref. 23, p p. 1, 30

3&4

- Methylphenol MCC

- WW04

- 11

- 100712 0.0695 0. 0 27 mg/L Ref. 22, pp. 15, 56; Ref. 23, p p. 1, 30

HRS Documentation Record US Oil Recovery 

### 35 T XN000607093Source Characterization

- Source 4

Hazardous Substance Evidence References Sample
ID Concentration RL/ MQL 1 Units

Phenol MCC

- WW04

- 11

- 100712 0.0814 0. 0 27 mg/L Ref. 22, pp. 15, 56; Ref. 23, p p. 1, 30 bis(2

- Ethylhexyl)phthalate MCC

- WW04

- 11

- 100712 0.0097 JQ 0. 0 27 mg/L Ref. 22, pp. 1 6

, 56; Ref. 23, p p. 1, 31 Antimony MCC

- WW04

- 11

- 100712 0.0053 0. 0 0 50 mg/L Ref. 22, pp.18, 56; Ref. 23, p p. 1, 57

Arsenic MCC

- WW04

- 11

- 100712 0.0068 0. 00 5 0 mg/L Ref. 22, pp.18, 56; Ref. 23, p p. 1, 57

Barium MCC

- WW04

- 11

- 100712 0.0090 JQ 0. 20 mg/L Ref. 22, pp.18, 56; Ref. 23, p p. 1, 57

Chromium MCC

- WW04

- 11

- 100712 0.0030 JQ 0. 0 10 mg/L Ref. 22, pp.18, 56; Ref. 23, p p. 1, 57

Cobalt MCC

- WW04

- 11

- 100712 0.0058 JQ 0. 0 50 mg/L Ref. 22, pp.18, 56; Ref. 23, p p. 1, 57

Lead MCC

- WW04

- 11

- 100712 0.0071 0. 00 30 mg/L Ref. 22, pp.18, 56; Ref. 23, p p. 1, 57 Manganese MCC

- WW04

- 11

- 100712 0. 01 44 JQ 0. 0 15 mg/L Ref. 22, pp.18, 56; Ref. 23, p p. 1, 57

Nickel MCC

- WW04

- 11

- 100712 0.0903 0. 0 40 mg/L Ref. 22, pp.18, 56; Ref. 23, p p. 1, 57

Selenium MCC

- WW04

- 11

- 100712 0.0028 JQK 0. 00 50 mg/L Ref. 22, pp.18, 56; Ref. 23, p p. 1, 57

Vanadium MCC

- WW04

- 11

- 100712 0.0023 JQ 0. 0 50 mg/L Ref. 22, pp.18, 56; Ref. 23, p p. 1, 57

Zinc MCC

- WW04

- 11

- 100712 0.0638 JK 0. 0 20 mg/L Ref. 22, pp.18, 56; Ref. 23, p p. 1, 57

Acetone MCC

- WW05

- 11

- 100712 0.137 0. 0 50 mg/L Ref. 22, pp. 19, 56; Ref. 23, p p. 1, 10

Carbon disulfide MCC

- WW05

- 11

- 100712 0.0089 0. 0020 mg/L Ref. 22, pp. 19, 56; Ref. 23, p p. 1, 10 Methyl ethyl ketone MCC

- WW05

- 11

- 100712 0.0288 JK 0. 0 10 mg/L Ref. 22, pp. 19, 56; Ref. 23, p p. 1, 10

Toluene MCC

- WW05

- 11

- 100712 0.00061 JQ 0. 00 20 mg/L Ref. 22, pp. 19, 56; Ref. 23, p p. 1, 10 Xylene (total) MCC

- WW05

- 11

- 100712 0.0026JQ 0. 00 60 mg/L Ref. 22, pp. 20 , 56; Ref. 23, p p. 1, 11

Benzoic acid MCC

- WW05

- 11

- 100712 0.357 0. 0 55 mg/L Ref. 22, pp. 21 , 56; Ref. 23, p p. 1, 33

2

- Methylphenol MCC

- WW05

- 11

- 100712 0.0116 JQ 0. 0 27 mg/L Ref. 22, pp. 21 , 56; Ref. 23, p p. 1, 33

3&4

- Methylphenol MCC

- WW05

- 11

- 100712 0.157 0. 0 27 mg/L Ref. 22, pp. 21 , 56; Ref. 23, p p. 1, 33

Phenol MCC

- WW05

- 11

- 100712 0.0259 JQ 0. 0 27 mg/L Ref. 22, pp. 21 , 56; Ref. 23, p p. 1, 33

Arsenic MCC

- WW05

- 11

- 100712 0. 009 4 0. 00 5 0 mg/L Ref. 22, pp. 24, 56; Ref. 23, p p. 1, 58

Chromium MCC

- WW05

- 11

- 100712 0.0079 JQ 0. 0 10 mg/L Ref. 22, pp. 24, 56; Ref. 23, p p. 1, 58

Cobalt MCC

- WW05

- 11

- 100712 0.0030 JQ 0. 0 50 mg/L Ref. 22, pp. 24, 56; Ref. 23, p p. 1, 58

Lead MCC

- WW05

- 11

- 100712 0.0064 0. 00 30 mg/L Ref. 22, pp. 24, 56; Ref. 23, p p. 1, 58 Manganese MCC

- WW05

- 11

- 100712 0.0195 0. 00 15 mg/L Ref. 22, pp. 24, 56; Ref. 23, p p. 1, 58

Nickel MCC

- WW05

- 11

- 100712 0.114 0. 0 40 mg/L Ref. 22, pp. 24, 56; Ref. 23, p p. 1, 58

Selenium MCC

- WW05

- 11

- 100712 0.0017 JQK 0. 00 50 mg/L Ref. 22, pp. 24, 56; Ref. 23, p p. 1, 58

Vanadium MCC

- WW05

- 11

- 100712 0.0051 JQ 0. 0 50 mg/L Ref. 22, pp. 24, 56; Ref. 23, p p. 1, 58

Zinc MCC

- WW05

- 11

- 100712 0.142 JK 0. 0 20 mg/L Ref. 22, pp. 24, 56; Ref. 23, p p. 1, 58

Acetone MCC

- WW06

- 11

- 100712 0.387 0. 0 50 mg/L Ref. 22, pp. 25, 57; Ref. 23, p p. 1, 12

Benzene MCC

- WW06

- 11

- 100712 0.0017 JQ 0.00 20 mg/L Ref. 22, pp. 25, 57; Ref. 23, p p. 1, 12

Carbon disulfide MCC

- WW06

- 11

- 100712 0.0097 0. 00 20 mg/L Ref. 22, pp. 25, 57; Ref. 23, p p. 1, 12

Ethylbenzene MCC

- WW06

- 11

- 100712 0.00079 JQ 0. 00 20 mg/L Ref. 22, pp. 25, 57; Ref. 23, p p. 1, 12

4- Methyl -2- pentanone MCC

- WW06

- 11

- 100712 0.013 JK 0. 0 10 mg/L Ref. 22, pp. 25, 57; Ref. 23 ,p p. 1, 12

Methyl ethyl ketone MCC

- WW06

- 11

- 100712 0.078 JK 0. 0 10 mg/L Ref. 22, pp. 25, 57; Ref. 23, p p. 1, 12

Toluene MCC

- WW06

- 11

- 100712 0.0015 JQ 0. 00 20 mg/L Ref. 22, pp. 25, 57; Ref. 23, p p. 1, 12

HRS Documentation Record US Oil Recovery 

### 36 T XN000607093Source Characterization

- Source 4

Hazardous Substance Evidence References Sample
ID Concentration RL/ MQL 1 Units

Xylene (total) MCC

- WW06

- 11

- 100712 0.0032 JQ 0. 00 60 mg/L Ref. 22, pp. 2 6 , 57; Ref. 23, p p. 1, 1 3

Benzoic acid MCC

- WW06

- 11

- 100712 0.366 0. 0 55 mg/L Ref. 22, pp. 2 7 , 57; Ref. 23, p p. 1, 36

2

- Methylphenol MCC

- WW06

- 11

- 100712 0.0299 0. 0 27 mg/L Ref. 22, pp. 2 7 , 57; Ref. 23, p p. 1, 36

3&4

- Methylphenol MCC

- WW06

- 11

- 100712 0.510 0. 0 27 mg/L Ref. 22, pp. 2 7 , 57; Ref. 23, p p. 1, 36

Phenol MCC

- WW06

- 11

- 100712 0.142 0. 0 27 mg/L Ref. 22, pp. 2 7 , 57; Ref. 23, p p. 1, 36

Arsenic MCC

- WW06

- 11

- 100712 0.0077 0. 00 5 0 mg/L Ref. 22, pp. 30 , 57; Ref. 23, p p. 1, 59

Barium MCC

- WW06

- 11

- 100712 0.0058 JQ 0. 20 mg/L Ref. 22, pp. 30 , 57; Ref. 23, p p. 1, 59

Chromium MCC

- WW06

- 11

- 100712 0.0070 JQ 0. 0 10 mg/L Ref. 22, pp. 30 , 57; Ref. 23, p p. 1, 59

Cobalt MCC

- WW06

- 11

- 100712 0.0026 JQ 0. 0 50 mg/L Ref. 22, pp. 30 , 57; Ref. 23, p p. 1, 59

Lead MCC

- WW06

- 11

- 100712 0.0069 0.00 30 mg/L Ref. 22, pp. 30 , 57; Ref. 23, p p. 1, 59 Manganese MCC

- WW06

- 11

- 100712 0.0483 0. 0 15 mg/L Ref. 22, pp. 30 , 57; Ref. 23, p p. 1, 59

Nickel MCC

- WW06

- 11

- 100712 0.0902 0. 0 40 mg/L Ref. 22, pp. 30 , 57; Ref. 23, p p. 1, 59

Selenium MCC

- WW06

- 11

- 100712 0.0027 JQK 0.00 50 mg/L Ref. 22, pp. 30 , 57; Ref. 23, p p. 1, 59

Vanadium MCC

- WW06

- 11

- 100712 0.0055 JQ 0. 0 50 mg/L Ref. 22, pp. 30 , 57; Ref. 23, p p. 1, 59

Zinc MCC

- WW06

- 11

- 100712 0.140 JK 0. 0 20 mg/L Ref. 22, pp. 30 , 57; Ref. 23, p p. 1, 59

Acetone MCC

- WW07

- 12

- 100712 0.450 0. 0 50 mg/L Ref. 22, pp. 31, 57; Ref. 23, p p. 1, 14

Benzene MCC

- WW07

- 12

- 100712 0.0019 JQ 0. 00 20 mg/L Ref. 22, pp. 31, 57; Ref. 23, p p. 1, 14

Carbon disulfide MCC

- WW07

- 12

- 100712 0.0082 0. 00 20 mg/L Ref. 22, pp. 31, 57; Ref. 23, p p. 1, 14

Ethylbenzene MCC

- WW07

- 12

- 100712 0.0012 JQ 0.00 20 mg/L Ref. 22, pp. 31, 57; Ref. 23, p p. 1, 14

4

- Methyl

- 2

- pentanone MCC

- WW07

- 12

- 100712 0.0152 0. 0 10 mg/L Ref. 22, pp. 31, 57; Ref. 23, p p. 1, 14

Methyl ethyl ketone MCC

- WW07

- 12

- 100712 0.0932 0. 0 10 mg/L Ref. 22, pp. 31, 57; Ref. 23, p p. 1, 14

Toluene MCC

- WW07

- 12

- 100712 0.002 0. 00 20 mg/L Ref. 22, pp. 31, 57; Ref. 23, p p. 1, 14 Xylene (total) MCC

- WW07

- 12

- 100712 0.0043 JQ 0. 006 mg/L Ref. 22, pp. 32, 57; Ref. 23, p p. 1, 15

Benzoic acid MCC

- WW07

- 12

- 100712 0.321 0. 0 55 mg/L Ref. 22, pp. 33, 57; Ref. 23, p p. 1, 39

2

- Methylphenol MCC

- WW07

- 12

- 100712 0.0232 JQ 0. 0 27 mg/L Ref. 22, pp. 33, 57; Ref. 23, p p. 1, 39

3&4

- Methylphenol MCC

- WW07

- 12

- 100712 0.362 0. 0 27 mg/L Ref. 22, pp. 33, 57; Ref. 23, p p. 1, 39

Phenol MCC

- WW07

- 12

- 100712 0.108 0. 0 27 mg/L Ref. 22, pp. 33, 57; Ref. 23, p p. 1, 39 bis(2

- Ethylhexyl)phthalate MCC

- WW07

- 12

- 100712 0.012 JQ 0. 0 27 mg/L Ref. 22, pp. 34, 57; Ref. 23, p p. 1, 40 Nap h thalene MCC

- WW07

- 12

- 100712 0.0068 JQ 0. 0 27 mg/L Ref. 22, pp. 34, 57; Ref. 23

, p p. 1, 40

Arsenic MCC

- WW07

- 12

- 100712 0.0082 0.00 50 mg/L Ref. 22, pp. 3 6 , 57; Ref. 23, p p. 1, 60

Barium MCC

- WW07

- 12

- 100712 0.0047 JQ 0. 20 mg/L Ref. 22, pp. 3 6 , 57; Ref. 23, p p. 1, 60

Chromium MCC

- WW07

- 12

- 100712 0.0069 JQ 0. 0 10 mg/L Ref. 22, pp. 3 6 , 57; Ref. 23, p p. 1, 60

Cobalt MCC

- WW07

- 12

- 100712 0.0025 JQ 0. 0 50 mg/L Ref. 22, pp. 3 6 , 57; Ref. 23, p p. 1, 60

Lead MCC

- WW07

- 12

- 100712 0.0069 0. 00 30 mg/L Ref. 22, pp. 3 6 , 57; Ref. 23, p p. 1, 60 Manganese MCC

- WW07

- 12

- 100712 0.0462 0. 0 15 mg/L Ref. 22, pp. 3 6 , 57; Ref. 23, p p. 1, 60

Nickel MCC

- WW07

- 12

- 100712 0.0901 0. 0 40 mg/L Ref. 22, pp. 3 6 , 57; Ref. 23, p p. 1, 60

Selenium MCC

- WW07

- 12

- 100712 0.0013 JQK 0. 00 50 mg/L Ref. 22, pp. 3 6 , 57; Ref. 23, p p. 1, 60

Vanadium MCC

- WW07

- 12

- 100712 0.0055 JQ 0. 0 50 mg/L Ref. 22, pp. 3 6 , 57; Ref. 23, p p. 1, 60

HRS Documentation Record US Oil Recovery 

### 37 T XN000607093Source Characterization

- Source 4

Hazardous Substance Evidence References Sample
ID Concentration RL/ MQL 1 Units

Zinc MCC

- WW07

- 12

- 100712 0.139 JK 0. 0 20 mg/L Ref. 22, pp. 3 6 , 57; Ref. 23, p p. 1, 60

Acetone MCC

- WW08

- 11

- 100712 18.5 JL 1.30 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16

Benzene MCC

- WW08

- 11

- 100712 3.13 JL 0. 0 50 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16

Chloroform MCC

- WW08

- 11

- 100712 0.0177 JL 0. 0 10 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16

Carbon disulfide MCC

- WW08

- 11

- 100712 0.032 JL 0. 0 10 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16
1,2

- Dichloroethane MCC

- WW08

- 11

- 100712 0.991 JL 0. 0 50 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16
1,2

- Dichloropropane MCC

- WW08

- 11

- 100712 0. 00 5 3 J Q L 0. 0 10 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16 Ethylbenzene MCC

- WW08

- 11

- 100712 1.92 JL 0. 0 50 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16

4

- Methyl

- 2

- pentanone MCC

- WW08

- 11

- 100712 2.10 JL 0.05 0 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16

Methylene chloride MCC

- WW08

- 11

- 100712 0.669 JL 0. 0 10 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16 Methyl ethyl ketone MCC

- WW08

- 11

- 100712 2.75 JL 0. 0 50 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16 Tetrachloroethylene MCC

- WW08

- 11

- 100712 0.0409 JL 0. 0 10 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16

Toluene MCC

- WW08

- 11

- 100712 3.38 JL 0. 0 50 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16 Trichloroethylene MCC

- WW08

- 11

- 100712 0.0479 JL 0. 0 10 mg/L Ref. 22, pp. 37, 57; Ref. 23, p p. 1, 16

Xylene (total) MCC

- WW08

- 11

- 100712 8.77 JL 0. 150 mg/L Ref. 22, pp. 38, 57; Ref. 23, p p. 1, 17

3&4

- Methylphenol MCC

- WW08

- 11

- 100712 1.34 1.1 mg/L Ref. 22, pp. 39, 57; Ref. 23, p p. 1, 42 Acenapthene MCC

- WW08

- 11

- 100712 0.847 JQ 1.1 mg/L Ref. 22, pp. 39, 57; Ref. 23, p p. 1, 42

Di

- n

- butyl phthalate MCC

- WW08

- 11

- 100712 0.377 JQ 1.1 mg/L Ref. 22, pp. 40, 57; Ref. 23, p p. 1, 43 bis(2

- Ethylhexyl)phthalate MCC

- WW08

- 11

- 100712 0.926 JQ 1.1 mg/L Ref. 22, pp. 40, 57; Ref. 23, p p. 1, 43

Fluorene MCC

- WW08

- 11

- 100712 0.465 JQ 1.1 mg/L Ref. 22, pp. 40, 57; Ref. 23, p p. 1, 43

2

- Methylnaphthalene MCC

- WW08

- 11

- 100712 9.44 1.1 mg/L Ref. 22, pp. 40, 57; Ref. 23, p p. 1, 43 Naphthalene MCC

- WW08

- 11

- 100712 32.0 5.4 mg/L Ref. 22, pp. 40, 57; Ref. 23, p p. 1, 43

Phenanthrene MCC

- WW08

- 11

- 100712 0.735 JQ 1.1 mg/L Ref. 22, pp. 40, 57; Ref. 23, p p. 1, 43

Antimony MCC

- WW08

- 11

- 100712 0.637 0. 00 5 0 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

Arsenic MCC

- WW08

- 11

- 100712 0.118 0. 00 5 0 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

Barium MCC

- WW08

- 11

- 100712 19.5 0. 20 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

Cadmium MCC

- WW08

- 11

- 100712 0.0155 0. 00 40 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

Chromium MCC

- WW08

- 11

- 100712 0.932 0. 0 10 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

Cobalt MCC

- WW08

- 11

- 100712 0.324 0. 0 50 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61 Copper MCC

- WW08

- 11

- 100712 2.56 0. 0 25 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

Lead MCC

- WW08

- 11

- 100712 1.11 0. 00 30 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61 Manganese MCC

- WW08

- 11

- 100712 1.91 0. 0 15 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

Mercury MCC

- WW08

- 11

- 100712 0.264 0. 0 20 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

Nickel MCC

- WW08

- 11

- 100712 1.89 0. 0 40 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

Selenium MCC

- WW08

- 11

- 100712 0.0129 JL 0. 00 50 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

Silver MCC

- WW08

- 11

- 100712 0.0227 0. 0 10 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

Vanadium MCC

- WW08

- 11

- 100712 0.548 0. 0 50 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

Zinc MCC

- WW08

- 11

- 100712 35.4 JK 0. 10 mg/L Ref. 22, pp. 42, 57; Ref. 23, p p. 1, 61

HRS Documentation Record US Oil Recovery 

### 38 T XN000607093Source Characterization

- Source 4

Hazardous Substance Evidence References Sample
ID Concentration RL/ MQL 1 Units

Acetone MCC

- WW09

- 11

- 10712 0.0783 JK 0. 0 50 mg/L Ref. 22, pp. 43, 57 Ref. 23, p p. 1, 18

Carbon disulfide MCC

- WW09

- 11

- 10712 0.0012 JQL 0. 00 20 mg/L Ref. 22, pp. 43, 57 Ref. 23, p p. 1, 18

Ethylbenzene MCC

- WW09

- 11

- 10712 0.00092 JQL 0. 00 20 mg/L Ref. 22, pp. 43, 57 Ref. 23, p p. 1, 18 Methyl ethyl ketone MCC

- WW09

- 11

- 10712 0.0087 JQL 0. 0 10 mg/L Ref. 22, pp. 43, 57 ; Ref. 23, p p. 1, 18

Toluene MCC

- WW09

- 11

- 10712 0.00081 JQL 0. 00 20 mg/L Ref. 22, pp. 43, 57 Ref. 23, p p. 1, 18 Xylene (total) MCC

- WW09

- 11

- 10712 0.004 JQL 0. 00 60 mg/L Ref. 22, pp. 44, 57 ; Ref. 23, p p. 1, 19

Chrysene MCC

- WW09

- 11

- 10712 0.0061 JQ 0. 0 27 mg/L Ref. 22, pp. 45, 57 ; Ref. 23, p p. 1, 45 bis(2

- Ethylhexyl)phthalate MCC

- WW09

- 11

- 10712 0.0337 0. 0 27 mg/L Ref. 22, pp. 46, 57 Ref. 23, p p. 1, 46 Pyrene MCC

- WW09

- 11

- 10712 0.0105 0. 0 27 mg/L Ref. 22, pp. 46, 57 Ref. 23, p p. 1, 46 Antimony MCC

- WW09

- 11

- 10712 0.0130 0. 00 50 mg/L Ref. 22, pp. 48, 58; Ref. 23, p p. 1, 62

Arsenic MCC

- WW09

- 11

- 10712 0.0083 0. 00 5 0 mg/L Ref. 22, pp. 48, 58; Ref. 23, p p. 1, 62

Barium MCC

- WW09

- 11

- 10712 0.0056 JQ 0. 20 mg/L Ref. 22, pp. 48, 58; Ref. 23, p p. 1, 62

Chromium MCC

- WW09

- 11

- 10712 0.0080 JQ 0. 0 10 mg/L Ref. 22, pp. 48, 58; Ref. 23, p p. 1, 62

Cobalt MCC

- WW09

- 11

- 10712 0.0183 JQ 0. 0 50 mg/L Ref. 22, pp. 48, 58; Ref. 23, p p. 1, 62

Lead MCC

- WW09

- 11

- 10712 0.0091 0. 00 30 mg/L Ref. 22, pp. 48, 58; Ref. 23, p p. 1, 62 Manganese MCC

- WW09

- 11

- 10712 0.0946 0. 0 15 mg/L Ref. 22, pp. 48, 58; Ref. 23, p p. 1, 62

Nickel MCC

- WW09

- 11

- 10712 0.271 0. 0 40 mg/L Ref. 22, pp. 48, 58; Ref. 23, p p. 1, 62

Selenium MCC

- WW09

- 11

- 10712 0.0020 JQK 0. 00 50 mg/L Ref. 22, pp. 48, 58; Ref. 23, p p. 1, 62

Vanadium MCC

- WW09

- 11

- 10712 0.0148 JQ 0. 0 50 mg/L Ref. 22, pp. 48, 58; Ref. 23, p p. 1, 62

Zinc MCC

- WW09

- 11

- 10712 0.0529 JK 0. 0 20 mg/L Ref. 22, pp. 48, 58; Ref. 23, p p. 1, 62 Bis(2

- Ethylhexyl)phthalate MCC

- WW10

- 11

- 100712 0.0018 JQ 0. 00 50 mg/L Ref. 22, pp.52, 58; Ref. 23, p p. 1, 49 Antimony MCC

- WW10

- 11

- 100712 0.0293 0. 00 5 0 mg/L Ref. 22, pp. 54, 58; Ref. 23, p p. 1, 63

Barium MCC

- WW10

- 11

- 100712 0.101 JQ 0. 20 mg/L Ref. 22, pp. 54, 58; Ref. 23, p p. 1, 63 Manganese MCC

- WW10

- 11

- 100712 0.134 0. 0 15 mg/L Ref. 22, pp. 54, 58; Ref. 23, p p. 1, 63

Nickel MCC

- WW10

- 11

- 100712 0.0016 JQ 0. 0 40 mg/L Ref. 22, pp. 54, 58; Ref. 23, p p. 1, 63

Selenium MCC

- WW10

- 11

- 100712 0.0014 JQK 0. 00 50 mg/L Ref. 22, pp. 54, 58; Ref. 23, p p. 1, 63

Zinc MCC

- WW10

- 11

- 100712 0.0762 JK 0. 020 mg/L Ref. 22, pp. 54, 58; Ref. 23, p p. 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. 1 60

, 325 ; Ref. 28, p. 73

Toluene WW

- 01

- 00

- 11

- 20110303 0.0335 J 0.002 mg/L Ref. 24, pp. 1 60

, 325 ; Ref. 28, p. 73 Ethylbenzene WW

- 01

- 00

- 11

- 20110303 0.0621 J 0.002 mg/L Ref. 24, pp. 1 60

, 325 ; Ref. 28, p. 73

meta

- /para

- Xylene WW

- 01

- 00

- 11

- 20110303 0.288 J 0.040 mg/L Ref. 24, pp. 1 60

, 325 ; Ref. 28, p. 73

HRS Documentation Record US Oil Recovery 

### 39 T XN000607093Source Characterization

- Source 4

Hazardous Substance Evidence References Sample
ID Concentration RL/ MQL 1 Units

ortho

- Xylene WW

- 01

- 00

- 11

- 20110303 0.093 J 0.002 mg/L Ref. 24, pp. 1 60

, 325 ; Ref. 28, p. 73

Benzoic acid WW

- 01

- 00

- 11

- 20110303 1.82 J 1.0 mg/L Ref. 24, pp. 1 61

, 325 ; Ref. 28, p. 73 bis(2

- Ethylhexyl)phthalate WW

- 01

- 00

- 11

- 20110303 0.0942 0.05 mg/L Ref. 24, pp. 1 61

, 325 ; Ref. 28, p. 73 Caprolactum WW

- 01

- 00

- 11

- 20110303 0.080 0.05 mg/L Ref. 24, pp. 1 61

, 325 ; Ref. 28, p. 73

2

- Methylphenol WW

- 01

- 00

- 11

- 20110303 0.0617 0.05 mg/L Ref. 24, pp. 1 62

, 325 ; Ref. 28, p. 73

3&/or4

- Methylphenol WW

- 01

- 00

- 11

- 20110303 0.732 0.05 mg/L Ref. 24, pp. 1 62

, 325 ; Ref. 28, p. 73 Naphthalene WW

- 01

- 00

- 11

- 20110303 1.45 0.2 mg/L Ref. 24, pp. 1 62

, 325 ; Ref. 28, p. 73

Phenol WW

- 01

- 00

- 11

- 20110303 0.774 0.05 mg/L Ref. 24, pp. 1 63

, 325 ; Ref. 28, p. 73 Manganese WW

- 01

- 00

- 11

- 20110303 0.116 0.050 mg/L Ref. 24, pp. 1 64

, 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. 12 4 , 325; Ref. 28, p. 72 Ethylbenzene SL

- 01

- 00

- 81 2.19 0.0998 mg/kg Ref. 24, pp. 12 4 , 325; Ref. 28, p. 72

meta

- /para

- Xylene SL

- 01

- 00

- 81 15.6 0.2 mg/kg Ref. 24, pp. 12 4 , 325; Ref. 28, p. 72

ortho

- Xylene SL

- 01

- 00

- 81 6.87 0.0998 mg/kg Ref. 24, pp. 12 4 , 325; Ref. 28, p. 72 Isopropylbenzene SL

- 01

- 00

- 81 0.429 0.0998 mg/kg Ref. 24, pp. 12 4 , 325; Ref. 28, p. 72

Acenaphthene SL

- 01

- 00

- 81 26.2 9.0 mg/kg Ref. 24, pp. 12 5 , 325; Ref. 28, p. 72
1,1’

- Biphenyl SL

- 01

- 00

- 81 52.4 22.5 mg/kg Ref. 24, pp. 12 5 , 325; Ref. 28, p. 72 Bis(2

- ethylhexyl)phthalate SL

- 01

- 00

- 81 93.3 22.5 mg/kg Ref. 24, pp. 12 5 , 325; Ref. 28, p. 72 Chrysene SL

- 01

- 00

- 81 31.2 22.5 mg/kg Ref. 24, pp. 12 6 , 325; Ref. 28, p. 72

Di

- n

- butyl phthalate SL

- 01

- 00

- 81 59.3 22.5 mg/kg Ref. 24, pp. 12 6 , 325; Ref. 28, p. 72

Fluoranthene SL

- 01

- 00

- 81 9.45 9.0 mg/kg Ref. 24, pp. 12 6 , 325; Ref. 28, p. 72

Fluorene SL

- 01

- 00

- 81 28.6 9.0 mg/kg Ref. 24, pp. 12 6 , 325; Ref. 28, p. 72

2

- Methylnaphthalene SL

- 01

- 00

- 81 95 9.0 mg/kg Ref. 24, pp. 12 6 , 325; Ref. 28, p. 72

3

- &/or4

- M e thylphenol SL

- 01

- 00

- 81 137 22.5 mg/kg Ref. 24, pp. 12 6 , 325; Ref. 28, p. 72 Naphthalene SL

- 01

- 00

- 81 140 9.0 mg/kg Ref. 24, pp. 12 6 , 325; Ref. 28, p. 72

Phenanthrene SL

- 01

- 00

- 81 35.4 9.0 mg/kg Ref. 24, pp. 12 7

, 325; Ref. 28, p. 72 Pyrene SL

- 01

- 00

- 81 52.2 9.0 mg/kg Ref. 24, pp. 12 7 , 325; Ref. 28, p. 72

Barium SL

- 01

- 00

- 81 190 24.6 mg/kg Ref. 24, pp. 12 8 , 325; Ref. 28, p. 72

Chromium SL

- 01

- 00

- 81 44.7 24.6 mg/kg Ref. 24, pp. 12 8 , 325; Ref. 28, p. 72

Copper SL

- 01

- 00

- 81 105 K 49.2 mg/kg Ref. 24, pp. 12 8 , 325; Ref. 28, p. 72 Manganese SL

- 01

- 00

- 81 87.2 K 12.3 mg/kg Ref. 24, pp. 12 8 , 325; Ref. 28, p. 72

Nickel SL

- 01

- 00

- 81 87.8 49.2 mg/kg Ref. 24, pp. 12 8 , 325; Ref. 28, p. 72

Zinc SL

- 01

- 00

- 81 1,890 49.2 mg/kg Ref. 24, pp. 12 8 , 325; Ref. 28, p. 72

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). Q The reported concentration is less t han 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

HRS Documentation Record US Oil Recovery 

### 40 T XN000607093Source Characterization

- Source 4

Quantitation Limit (SQL). No b ias 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 a n 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 t o 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: Hazard ous 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 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, Figur e A-2B; Ref. 13, pp. 1-4):

Reservoir Name Location Volume (gallons) Gravity Thickener Located on east ern 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 east ern side of 200 N. Richey Street property on north side 305,624

Clarifier #2 Located on east ern side of 200 N. Richey Street property on north side 297,141

Chlorine Contact Tank Located on east ern side of 200 N. Richey Street property on northwest side 143,640

Oxygen Digester #1 Located on east ern side of 200 N. Richey Street property centrally located south of clarifiers 90

, 589

HRS Documentation Record US Oil Recovery 

### 41 T XN000607093Source Characterization

- Source 4

Reservoir Name Location Volume (gallons) Oxygen Digester #2 Located on east ern 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 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).

Tier Evaluated Source 4 Values
A Not Evaluated
B Not Evaluated
C 2,605.912
D 0



### Source Hazardous Waste Quantity Value: 2,605.912

HRS Documentation Record US Oil Recovery 

### 42 T XN000607093Source Characterization

- Source 5



### 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. 6-1 0).

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

are as 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, p p. 18, 25; Ref. 43, pp. 6-10).

HRS Documentation Record US Oil Recovery 

### 43 T XN000607093Source Characterization

- Source 5



### 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 ISM0 5.3 by the EPA Region 6 Environmen tal Services Branch Laboratory (Ref. 28, p. 74; Ref. 24, pp. 183-194, 326 ).

An alytical 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 1 Units

EPA Supplemental Sampling Activities – March 2011

Acetone T0126

- 00

- 81 4,300 J 2,500 mg/L Ref. 24, p p . 1 83, 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. 18 4 , 326; Ref. 28, p. 73

Toluene T0126

- 00

- 81 2.51 J 2 mg/L Ref. 24, pp. 18 4 , 326; Ref. 28, p. 73 Ethylbenzene T0126

- 00

- 81 3.6 J 2 mg/L Ref. 24, pp. 18 4 , 326; Ref. 28, p. 73

meta

- /para

- Xylene T0126

- 00

- 81 13.1 J 4 mg/L Ref. 24, pp. 18 4 , 326; Ref. 28, p. 73

ortho

- Xylene T0126

- 00

- 81 5.81 J 2 mg/L Ref. 24, pp. 18 4 , 326; Ref. 28, p. 73 Benzyl alcohol T0126

- 00

- 81 47.1 5 mg/L Ref. 24, pp. 18 5 , 326; Ref. 28, p. 73 Butyl benzyl phthalate T0126

- 00

- 81 12.8 5 mg/L Ref. 24, pp. 18 5 , 326; Ref. 28, p. 73

Naphthalene T0126

- 00

- 81 3.14 2 mg/L Ref. 24, pp. 18 6 , 326; Ref. 28, p. 73

Phenol T0126

- 00

- 81 20.1 J 5 mg/L Ref. 24, pp. 18 7 , 326; Ref. 28, p. 73

Chromium T0126

- 00

- 81 3.26 0.0806 mg/L Ref. 24, pp. 18 8 , 326; Ref. 28, p. 73

Zinc T0126

- 00

- 81 0.192 0.161 mg/L Ref. 24, pp. 18 8 , 326; Ref. 28, p. 73 Benzaldehyde T0212

- 00

- 81 0.787 BJ 0.755 mg/kg Ref. 24, pp. 1 91 , 326; Ref. 28, p. 73

Phenol T0212

- 00

- 81 0.864 BJ 0.755 mg/kg Ref. 24, pp. 1 93 , 326; Ref. 28, p. 73

HRS Documentation Record US Oil Recovery 

### 44 T XN0006070931 Source Characterization

- Source 5

Hazardous Substance Evidence References Sample ID Concentration Reporting Limit 1 Units

Methyl acetate T0212

- 00

- 81 4.78 0.25 mg/kg Ref. 24, pp. 18 9 , 326; Ref. 28, p. 73

Chromium T0212

- 00

- 81 88.1 13.2 mg/kg Ref. 24, pp. 1 94 , 326; Ref. 28, p. 73 Manganese T0212

- 00

- 81 551 K 6.6 mg/kg Ref. 24, pp. 1 94 , 326; Ref. 28, p. 73

Nickel T0212

- 00

- 81 205 26.3 mg/kg Ref. 24, pp. 1 94 , 326; Ref. 28, p. 73

Vanadium T0212

- 00

- 81 32.7 26.3 mg/kg Ref. 24, pp. 1 94 , 326; Ref. 28, p. 73

Zinc T0212

- 00

- 81 32.7 26.3 mg/kg Ref. 24, pp. 1 94 , 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 ident ification 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).

The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory i s 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

w arehouse 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 sto red 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 (Re f. 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 r esponse 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).

HRS Documentation Record US Oil Recovery 

### 45 T XN000607093Source Characterization

- Source 5

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

Subt otal Volume of Liquids 23,360

Corrosive Acid Gel 8 Ref. 10, p. 84

Flammable Gel 440 Ref. 10, pp. 74, 84

Subt otal Volume of Gel 448

Flammable, Corrosive Acid Liquid/Solid 40 Ref. 10, p. 86

Subt otal Volume of Liquid/Solids 40

Corrosive Acid Solid 120 Ref. 10, p. 84

Flammable Solid 140 Ref. 10, pp. 80, 86

Subt otal 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)

T ier 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

HRS Documentation Record US Oil Recovery 

### 46 T XN000607093Source Characterization

- Source 5



### 2.4.2.1.4 Tier D: Area - Not Evaluated (NE)

T ier 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 Source Hazardous Waste Quantity Value

Per th e HRS, the highest of the values assigned to the source for hazardous constituent quantity (Tier A), hazardous wastestream quantity (Tier B), v olume (Tier C), and a rea (Tier D) should be assigned as the source hazardous waste quantity value (Ref. 1, Sectio n 2.4.2.1.5).

Tier Evaluated Source 5 Values
A Not Evaluated
B 48.216
C Not Evaluated
D Not Evaluated



### Source Hazardous Waste Quantity Value: 48.216

HRS Documentation Record US Oil Recovery 

### 47 T XN000607093Source Characterization

- Source 6



### 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 ). T hese tanks have a combined storage capacity of approxima tely 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 brea k 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 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 be rm . 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).

Source Containment

Release To Surface Water

During an EPA Compliance Evaluation Inspection in November 2009, it was noted that the vents for

HRS Documentation Record US Oil Recovery 

### 48 T XN000607093Source Characterization

- Source 6



### 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 AS Ts 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 l ot (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 tha t 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 o f 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

- hazard ous 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 s amples 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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- Source 6



### 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 ISM0 5.3 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).

A nalytical 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 References Sample ID Concentration MQL/RL 1 Units

EPA Emergency Response Activities – November 2010 2

Benzene WP 01

- 71

- 101115 3.75 3 0.25 mg/L Ref. 45, pp. 8, 24; Ref.49, pp. 1,6 Methyl ethyl ketone WP 01

- 71

- 101115 0.695 3 0.50 mg/L Ref. 45, pp. 8, 24; Ref.49, pp. 1,6

2

- Methylphenol WP 01

- 71

- 101115 0.0878 3 0.050 mg/L Ref. 45, pp. 9, 24;Ref.49, pp. 9,14

3&4

- Methylphenol WP 01

- 71

- 101115 0.471 3 0.050 mg/L Ref. 45, pp. 9 , 24; Ref.49, pp. 9, 14

Arsenic WP 01

- 71

- 101115 0.027 B 3 0.050 mg/L Ref. 45, pp. 10, 24; Ref.49, p. 17

Barium WP 01

- 71

- 101115 0.42 B 3 5.0 mg/L Ref. 45, pp. 10, 24; Ref.49, p. 17

Lead WP 01

- 71

- 101115 0.011 B 3 0.025 mg/L Ref. 45, pp. 10, 24; Ref.49, p. 17

Arsenic WP 01

- 71

- 101115 39.3 0.83 mg/kg Ref. 45, pp. 1 2

, 24; Ref.49, pp. 17, 22

Barium WP 01

- 71

- 101115 1790 17 mg/kg Ref. 45, pp. 1 2 , 24; Ref.49, pp. 17, 22

Cadmium WP 01

- 71

- 101115 1.2 0.41 mg/kg Ref. 45, pp. 1 2 , 24; Ref.49, pp. 17, 22

Chromium WP 01

- 71

- 101115 78.7 0.83 mg/kg Ref. 45, pp. 1 2 , 24; Ref.49, pp. 17, 22

Lead WP 01

- 71

- 101115 133 0.83 mg/kg Ref. 45, pp. 1 2 , 24; Ref.49, pp. 17, 22 Mercury WP 01

- 71

- 101115 15.3 1.2 mg/kg Ref. 45, pp. 1 2 , 24; Ref.49, pp. 17, 22

Silver WP 01

- 71

- 101115 1.5 0.83 mg/kg Ref. 45, pp. 1 2 , 24; Ref.49, pp. 17, 22

Benzene WP 02- 71

- 10111 6 0.0322 3 0.25 mg/L Ref. 45, pp. 13, 24; Ref.49, pp. 1,7 Methyl ethyl ketone WP 0 2

- 71

- 10111 6 0.702 3 0.50 mg/L Ref. 45, pp. 13, 24; Ref.49, pp. 1,7

2

- Methylphenol WP 0 2

- 71

- 10111 6 0.0384 3 0.050 mg/L Ref. 45, pp. 14, 24; Ref.49, pp. 9, 15

3& 4- Methylphenol WP 02- 71

- 10111 6 0.232 3 0.050 mg/L Ref. 45, pp. 14, 24; Ref.49, pp. 9, 15

Arsenic WP 0 2

- 71

- 10111 6 0.023 B 3 0.050 mg/L Ref. 45, pp. 15, 24; Ref.49, p. 17

Barium WP 0 2

- 71

- 10111 6 0.15 B 3 5.0 mg/L Ref. 45, pp. 15, 24; Ref.49, p. 17

Chromium WP 0 2

- 71

- 10111 6 0.015 B 3 0.050 mg/L Ref. 45, pp. 15, 24; Ref.49, p. 17

Lead WP 0 2

- 71

- 10111 6 0.012 B 3 0.025 mg/L Ref. 45, pp. 15, 24; Ref.49, p. 17 Mercury WP 0 2

- 71

- 10111 6 0.0096 3 0.0020 mg/L Ref. 45, pp. 15, 24; Ref.49, p. 17

Selenium WP 0 2

- 71

- 10111 6 0.029 B 3 0.25 mg/L Ref. 45, pp. 15, 24; Ref.49, p. 17

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### 50 T XN000607093Source Characterization

- Source 6

Hazardous Substance Evidence References Sample ID Concentration MQL/RL 1 Units

Arsenic WP 0 2

- 71

- 10111 6 13.7 1.4 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 23

Barium WP 0 2

- 71

- 10111 6 1720 28 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 23

Cadmium WP 02- 71

- 10111 6 1.6 0.69 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 23

Chromium WP 0 2

- 71

- 10111 6 101 1.4 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 23

Lead WP 0 2

- 71

- 10111 6 96.6 1.4 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 23 Mercury WP 0 2

- 71

- 10111 6 45.1 2.1 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 23

Selenium WP 0 2

- 71

- 10111 6 0.46 B 1.4 mg/kg Ref. 45, pp. 17, 24; Ref.49, pp. 17, 23

Silver WP 0 2

- 71

- 10111 6 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

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### 51 T XN000607093Source Characterization

- Source 6

Hazardous Substance Evidence References Sample ID Concentration MQL/RL 1 Units

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

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### 52 T XN000607093Source Characterization

- Source 6

Hazardous Substance Evidence References Sample ID Concentration MQL/RL 1 Units

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 limit s which have been adjusted for sample aliquot, sample v olume, 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, 2 1 , 31).
3 These concentrations reported from the TCLP Leachate of the sample.

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### 53 T XN000607093Source Characterization

- Source 6



### 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)

T he 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: V olume

Two of the 17,000 gallon ASTs were sampled and found to contain hazardous substances through sampling ( Ref. 24, p p. 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 ). T he 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), volu me (Tier C), and area (Tier D) should be assigned as the source hazardous waste quantity value (Ref. 1, Section 2.4.2.1.5).

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### 54 T XN000607093Source Characterization

- Source 6

Tier Evaluated Source 6 Values
A Not Evaluated
B Not Evaluated
C 67.337
D 0



### Source Hazar dous Waste Quantity Value: 67.337

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### 55 T XN000607093Source Characterization

- Source 7



### 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 v alve 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).

Source Containment

Release to Surface Water

During a 0 2 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 0 2 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 a nd 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

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 w as hand

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### 56 T XN000607093Source Characterization

- Source 7



### delivered to Accutest Laboratories located in Houston, Texas. The sample w as 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, p p. 7-12, 16 , 17 ). Sample results for the containment pond indicate that the pond contained c oncentrations of acetone, phthalates and metals (Ref. 33, pp. 5, 15, 22 ).

A nalytical 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 1 mg/ L

EPA Emergency Response Activities – July 2010 2

Acetone SWP

- 05072010 0.0082 JQ 0. 050 Ref. 32, p. 16; Ref. 33, p p

. 1, 5

Di

- n

- butyl phthalate SWP

- 05072010 0.0011 JQ 0. 005 Ref. 32, p. 16; Ref. 33, p p

. 1,15 Bis(2

- Ethylhexyl)phthalate SWP

- 05072010 0.0041 JQ 0. 005 Ref. 32, p. 16; Ref. 33, p p

. 1,15

Arsenic SWP

- 05072010 0.0123 0. 0050 Ref. 32, p. 16; Ref. 33, p p

. 1,22

Barium SWP

- 05072010 0.0509 JQ 0. 20 Ref. 32, p. 16; Ref. 33, p p

. 1,22 Manganese SWP

- 05072010 0.108 0. 015 Ref. 32, p. 16; Ref. 33, p p

. 1,22

Nickel SWP

- 05072010 0.0428 0.040 Ref. 32, p. 16; Ref. 33, p p

. 1,22

Vanadium SWP

- 05072010 0.0018 JQ 0. 050 Ref. 32, p. 16; Ref. 33, p p

. 1,22

Zinc SWP

- 05072010 0.0417 0. 0 20 Ref. 32, p. 16; Ref. 33, p p

. 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 ).

HRS Documentation Record US Oil Recovery 

### 57 T XN000607093Source Characterization

- Source 7



### 2.4.2 Hazardous Waste Quantity

2.4.2.1 Source Hazardous Waste Q uantity

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

T he 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).

HRS Documentation Record US Oil Recovery 

### 58 T XN000607093Source Characterization

- Source 7

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

HRS Documentation Record US Oil Recovery 

### 59 T XN000607093Source Characterization

- Source 8



### 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.

T wo hundred twenty

- five 20 to 25- cubic yard roll

- off boxes are located throughout the property at 400 N. Richey Street. Most of t hese 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 tarp s, 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, the se 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 on

site (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).

Source Location

The roll

- off boxes are on the property at 400 N. Richey Street and are staged on the parking lots north,

HRS Documentation Record US Oil Recovery 

### 60 T XN000607093Source Characterization

- Source 8



### south, and east of the office/warehouse building (Ref. 8, pp. 4-5; Ref. 9, p. 6; Figure A- 2A).

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 stor mwater 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 Investiga tion 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 roll

off 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 -s ite (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 b y CLP ISM0 5.3 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.

Hazardous Substance Evidence References Sample ID Concentration (mg/kg) Reporting Limit 1 (mg/kg) EPA Supplemental Sampling Activities – March 2011

Acetone RO132

- 01

- 00

- 81 5.18 1.59 Ref. 24, pp. 207, 327; Ref. 28, p.73

HRS Documentation Record US Oil Recovery 

### 61 T XN000607093Source Characterization

- Source 8

Hazardous Substance Evidence References Sample ID Concentration (mg/kg) Reporting Limit 1 (mg/kg) Methylene chloride 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:

HRS Documentation Record US Oil Recovery 

### 62 T XN0006070931 Source Characterization

- Source 8

(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). The Reporting Limit (RL) terminology used by the EPA Region 6 Laboratory is a detection limit which has been adjusted for sam ple 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 informati on 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

Durin g 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 c ubic 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

HRS Documentation Record US Oil Recovery 

### 63 T XN000607093Source Characterization

- Source 8



### 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

Tier Evaluated Source 8 Values
A Not Evaluated
B Not Evaluated
C 1,133.3
D 0



### Source Hazardous Waste Quantity Value: 1,133.3

HRS Documentation Record US Oil Recovery 

### 64 T XN000607093Source Characterization



### SITE SUMMARY OF SOURCE DESCRIPTIONS

Source

No. 1 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

NE = Not Evaluated
1 = In addition to these sources, another source (Source 8) is discussed in section 2.2 of this HRS documentation record.

HRS Documentation Record US Oil Recovery 

### 65 T XN000607093Ground Water Pathway – Not Sco red


### 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.

HRS Documentation Record US Oil Recovery 

### 66 T XN000607093SW Pathway – Overland/Flood Migration


### 4.0 SURFACE WATER MIGRATION PATHWAY

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

4.1.1 General Considerations

4.1.1.1 Definition of Hazardous Substan ce Migration Path for Overland/F lood 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 Figure s 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 Ba you (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 t he 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 plan t runs west towards the bayou ( Ref. 6 , pp. 27, 788 ).

Source 1 – Drums (F lammable and Corrosive) For S ource 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

HRS Documentation Record US Oil Recovery 

### 67 T XN000607093SW Pathway – Overland/Flood Migration 

### 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 condition s (Ref. 6, pp. 10 4, 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 loc ated 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 S ource 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; R ef. 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

HRS Documentation Record US Oil Recovery 

### 68 T XN000607093SW Pathway – Overland/Flood Migration 

### 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 downgr adiant 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 t o the north approximat ely 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 a t 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 Bay ou, 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 fa rthest downstream PPE (i.e., PPE -06A ) in the in

- water segment section (Ref. 1, Sec. 4.1.1.2). The TDL of the s urface water flow path is presented in Attachment A, Figure A -4 and is described in the following paragraphs.

Drainage from Sources 1 thr ough 8 enters Vince Bayou at PPE -01 through PPE -06A ( refer to Attachment A, Figure A -3 ). From PPE

- 1, the f a rthest 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 B ay, 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).

HRS Documentation Record US Oil Recovery 

### 69 T XN000607093SW Pathway – Likelihood of Release



### 4.2 LIKELIHOOD OF RELEASE

4.2.1 Observed Release

Direct Observation

Direct observation has been established through materials seen entering the surface water by both migration and direct deposition. A dditionally , evidence of source s 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 sample s labeled as Unknown, NA

- 26 from a black effluent which emitted a slight chemical odor and was observed flowing into Vince Bayou. These sample s 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- pent anone, 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).

Hazardous Substance Evidence References Sample ID 1 Concentration 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

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### 70 T XN000607093SW Pathway – Likelihood of Release

Hazardous Substance Evidence References Sample ID 1 Concentration 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) 0.052 D 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

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Hazardous Substance Evidence References Sample ID 1 Concentration 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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### 72 T XN000607093SW Pathway – Likelihood of Release

Hazardous Substance Evidence References Sample ID 1 Concentration 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 = 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 wastew ater into the waters of the State. W astewater 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 ; b oth 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 samp led on 8 January 2010 ( labeled Discharge to Bayou) and 13 January 2010 (44028 -01 and -02) (Ref. 12, p. 2 1 ). 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).

Hazardous Substance Evidence References Sample ID Concentration Units

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 V ince 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 s ample 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 s ite 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 References Sample ID Concentration RL Units

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).

C hemical Analysis

Surface water and sediment samples were collected during the March 2011 supplemental s ampling

a ctivities conducted by EPA START -3 (Ref. 44, p. 4 ) . A total of 21 s urface water and s ediment samples were collected from the surface water pathway at 19 locations within Vince and Little Vince Bayou s. 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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### 74 T XN000607093SW Pathway – Likelihood of Release



### 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 sample s 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 backgrou nd surface water and sediment samples were collected on 0 1 and 0 3 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 d emonstrate 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 Laborator y for analysis of VOCs and SVOCs. S urface 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 an d 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 Sampl e Descriptions March 2011

Station Location

(Sample ID .) Sampl e Location Sample Date (Military Time) Reference

Surface Water

BG

- 02 (F 3SD9/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 ( F 3SJ6/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 A

5
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 Concen tration 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) 2 0.002 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, 6 0 Barium MF3SF3 81.0 7.0 Ref. 40, pp. 8, 17, 27, 6 0 Chromium MF3SF3 16.2 J 1.4 Ref. 40, pp. 8, 17, 27, 6 0 Cobalt MF3SF3 4.3 J 0.70 Ref. 40, pp. 8, 17, 27, 6 0 Copper MF3SF3 16.7 J 1.4 Ref. 40, pp. 8, 17, 27, 6 0 Lead MF3SF3 50.5 J 0.70 Ref. 40, pp. 8, 17, 27, 6 0 Manganese MF3SF3 158 J 0.70 Ref. 40, pp. 8, 17, 27, 6 0 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, 6 0 Nickel MF3SF3 7.8 J 0.70 Ref. 40, pp. 8, 17, 27, 6 0 Vanadium MF3SF3 16.1 J 3.5 Ref. 40, pp. 8, 17, 27, 6 0

Zinc MF3SF3 74.0 J

- (111) 2 1.4 Ref. 21, pp. 8, 18; Ref. 40, pp. 8, 17, 27, 6 0

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### Summary of USOR Designated Background Levels

Hazardous Substance Evidence Reference

Station Location/ Sample ID Concen tration 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 Th e 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 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 e stimated because of outlying quality control parameters or the result is below the CRQL ( Ref. 38 , p. 1 1, Ref. 4 0 , p. 1 1, Ref. 4 1 , p. 1 1, Ref. 42, p. 12). L Reported concentration between the MDL and the CRQL ( Ref. 38 , p. 1 1, Ref. 4 0 , p. 1 1, Ref. 4 1 , p. 1 1, Ref. 42, p. 12).

- Low biased ( Ref. 38 , p. 1 1, Ref. 4 0 , p. 1 1, Ref. 4 1 , p. 1 1, Ref. 42, p. 12).

+ High biased ( Ref. 38 , p. 1 1, Ref. 4 0 , p. 1 1, Ref. 4 1 , p. 1 1, Ref. 42, p. 12).

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### 78 T XN000607093SW Pathway – Likelihood of Release



### Samples collected from Vince Bayou above and below the confluence of Litt le 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 0.0149 mg/L 0.0447 mg/L Barium 0.0728 mg/L 0.2184 mg/L

Iron 0.160 J mg/L 0.20 mg/L Lead 0.0016 mg/L 0.0048 mg/L Manganese 0.0426 mg/L 0.1278 mg/L

Nickel 0.0039 mg/L 0.0117 mg/L Silver 0.0017 mg/L 0.0051 mg/L Zinc 0.018189 mg/L 0.054567 mg/L Little Vince Bayou Surface Water Chloroform 0.00057 mg/L 0.00171 mg/L Arsenic 0.021 J mg/L 0.063 mg/L Barium 0.0582 J mg/L 0.1746 mg/L Manganese 0.0352 mg/L 0.1056 mg/L Zinc 0.0201 J mg/L 0.0603 mg/L Vince Bayou Sediment Benzo(a)anthracene 1.16 mg/kg 3.48 mg/kg Benzo(a)pyrene 1.74 mg/kg 5.22 mg/kg Benzi(b)fluoranthene 1.9 mg/kg 5.7 mg/kg Benzo(g,h,i)perylene 1.37 mg/kg 4.11 mg/kg Benzo(k)fluoranthen e 1.39 mg/kg 4.17 mg/kg Bis(2

- ethylhexyl)phthalale 0.694 U mg/kg 0.0694 mg/kg Chrysene 1.75 mg/kg 5.25 mg/kg Fluoranthene 2.53 mg/kg 7.59 mg/kg Indeno(1,2,3

- cd)pyrene 1.16 mg/kg 3.48 mg/kg

2- Methylnaphthalene 0.278 U mg/kg 0.278 mg/kg Naphthalene 0.278 U mg/kg 0.278 mg/kg Phenanthrene 0.75 mg/kg 2.25 mg/kg Pyrene 2.74 mg/kg 8.22 mg/kg Arsenic 2.3 mg/kg 6.9 mg/kg Barium 81 mg/kg 243 mg/kg Chromium 16.2 mg/kg 448.6 mg/kg

Cobalt 4.3 mg/kg 12.9 mg/kg Copper 16.7 mg/kg 50.1 mg/kg

Iron 12,600 mg/kg 37,800 mg/kg Lead 50.5 mg/kg 151.5 mg/kg Manganese 158 mg/kg 474 mg/kg

Mercury 0.076 J mg/kg .228 mg /kg

Silver 0.70 U mg/kg 0.70 mg/kg Nickel 7.8 mg/kg 23.4 mg/kg Vanadium 16.1 mg/kg 48.3 mg/kg Zinc 111 mg/kg 333 mg/kg

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### 79 T XN000607093SW Pathway – Likelihood of Release

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 0.629 U mg/kg 0.629 mg/kg 2- Methylnaphthalene 0.252 U mg/kg 0.252 mg/kg Naphthalene 0.252 U mg/kg 0.252 mg/kg

Arsenic 2.3 mg/kg 6.9 mg/kg Barium 196 mg/kg 588 mg/kg Beryllium 0.81 mg/kg 2.43 mg/kg Chromium 12.4 mg/kg 37.2 mg/kg

Cobalt 4.3 mg/kg 12.9 mg/kg Copper 5.9 mg/kg 17.7 mg/kg

Iron 15,200 mg/kg 45,600 mg/kg Lead 10.3 mg/kg 30.9 mg/kg Manganese 148 mg/kg 444 mg/kg

Mercury 0.0083 LJ mg/kg 0.13 mg/kg Nickel 9.5 mg/kg 28.5 mg/kg Silver 0.65 U m g/kg 0.65 mg/kg Vanadium 20.1 mg/kg 60.3 mg/kg Zinc 16.9 mg/kg 50.7 mg/kg

Note s : 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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### 80 T XN000607093SW Pathway – Likelihood of Release



### Observed Release Samples:

S amples 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 ). S ampling locations with hazardous substances meeting observed r elease criteria are presented below.

EPA Supplemental Sampling Event – March 2011

Station Location

(Sample ID ) Sampl e 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/MF3S H2 ) 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 (MF3S H5 /MF3S H4 ) 150 feet upgradient from PPE

- 01 and 440 feet downstream of PPE

- 02 in Vince Bayou 03/03/2011 (0950/095 4 Ref. 28, p. 72;Ref. 34; Ref. 42

, pp

. 29, 30

SW

- 04 (MF3S H7 /MF3SH6) 340 feet upgradient from PPE -01 and 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 03/0 3 /2011 (1 037 ) Ref. 28, p. 7 2 ;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 (MF3S J0) 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 ea s ter n side of 200 N. Richey Street property into Vince Bayou 03/01&02/2011 (1442/ 093 7) 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 132 5 /100 6) Ref. 24, p. 322; R ef. 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/ 110 7) Ref. 24, p. 322; Ref. 28, pp. 69

, 70;Ref. 34; Ref. 42, p. 26

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### 81 T XN000607093SW Pathway – Likelihood of Release



### The surface water and sediment samples were collected on 0 1 and 0 3 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 sa mple 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 Laborator y for analysis of VOCs and SVOCs. S urface 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 2 mg/L Adjusted CRQL 1

mg/L Reference

SW

- 03 (MF3S H4 ) 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 hav e 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).

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### 82 T XN000607093SW Pathway – Likelihood of Release



### EPA Supplemental Sampling Event – March 2011 Sediment Samples – Vince Bayou

Station Location

(Sample ID) Hazardous Substance Concentr ation mg/kg Adjusted CRQL 1 mg/kg Reference

SW

- 01 (SED

- 01

- 03

- 51) Bis(2

- ethylhexyl)phthalate 0.904 B 0.695 Ref. 24, p p

. 80, 323

SW

- 01 (MF3SG2) Arsenic 13.1 J 0.82 Ref. 40, pp. 8, 19, 25

SW

- 02 (MF 3SG4 ) 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, 3 5 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, p p . 4 8, 323 Bis (2

- ethylhexyl)phthalate 7.45 0.772 Ref. 24, p p

. 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, p p . 5 5 , 323

PPE

- 05 (PPE

- 05

- 03

- 51) Bis (2

- ethylhexyl)phthalate 1.88 1.01 Ref. 24, p p

. 60 , 322

2

- Methlynaphthalene 0.544 0.406 Ref. 24, p p . 6 1 ,322 Naphthalene 0.416 0.406 Ref. 24, p p . 6 1 , 322
PPE

- 05 field duplicate (PPE

- 05

- 03

- 52) Bis (2

- ethylhexyl)phthalate 1.97 0.776 Ref. 24, p p. 6 5 , 322

PPE

- 06 (MF3SF5/ PPE

06

- 03

- 51) Bis (2

- ethylhexyl)phthalate 1.95 0.831 Ref. 24, p p. 70 , 322

Notes:

1 The Adjusted Contract Required Quantitation Limit (CRQL) terminology used by the CLP Laboratory is detection limits which hav e been adjusted for

sample aliquot, sample volume, and dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Secti on 1.1, Table 2

- 3; Ref. 24, p. 3; Ref. 26). B Blank related – the concentration found in the sample was less than 10x the concentration found in the associated extraction, digestion and/o r analysis

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### 83 T XN000607093SW Pathway – Likelihood of Release

blank (Ref. 24

, p. 328). J Result is estimated because of outlying quality control parameters (Ref. 4 0 , p. 1 1, Ref. 4 1 , p. 1 1 ).



### 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 site s in the TCEQ P reliminary A ssessments (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 individua l, 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 migrati on from site sources to the surface water pathway (Ref. 29, p. 14). The following soil samples are included to support migration of site

related contamination along the overland flow segment s from the source s 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

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### 84 T XN000607093SW Pathway – Likelihood of Release

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 PPE s only. The analytical results from these samples were not used to
score t he site, but to support attribution.

Station Location (CLP Sample No.) Hazardous Substance 2 Concentration mg/kg Adjusted CRQL 1 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

SS

- 03 field duplicate (MF3SD6) 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
Vanadium 65.9 J 65 Ref. 40, pp. 8, 14, 23, 46

SS

- 03 (MF3SD5) 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

Mercury 0.15 0.13 Ref. 40, pp. 8, 14, 23, 43
SS

- 04 (MF3SD4) Antimony 1.8 J 1.7 Ref. 40, pp. 8, 14, 23, 42
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 (MF3SD2) Mercury 0.66 0.12 Ref. 40, pp. 8, 13, 23, 37
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 hav e been adjusted for sample aliquot, sample volume, and dilutions for the analysis and meet the HRS definition of SQL (Ref. 1, Secti on 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 ha ve demonstrated to cause arsenic, barium, cobalt, manganese, mercury, silver, and vanadium contamination as sho wn 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, manga nese, mercury, silver, and vanadium contamination migration from sources at the site into the surface water pathway, the arsenic, cobalt, manganese, mercury, silver, and

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### 85 T XN000607093SW Pathway – Likelihood of Release



### 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, t he 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 t he 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 bodi es which are tidally inf luenced 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 ar e expected to occur (Ref. 3, pp. 1- 3).

A search of the Toxic Release Inventory and EPA EnviroMapper database s were performed within the zip code of the site location. The facilities identified upgradient along Vince Bayou included: Mac d ermid 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 produ ced labels; Naylor Industrial Services an inactive general freight trucking company; and Exxon Company an inactive petroleum facility . N o 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 substance s 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 V alue: 550

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### 86 T XN000607093SW Pathway – Potential to Release



### 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).

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### 87 T XN000607093SW Pathway

– Human Food Chain Threat/Waste Characteristics



### 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 establi shing 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 Value 1 Bioaccumulation Value
Fresh 2 Bioaccumulation Value
Salt 2 Toxicity/ Persistence/ Bioaccumulation

Factor Value Reference

Arsenic 3,4,7,OR 10,000 1 5 500 5 x 10 6 Ref. 2, p.1 Bis(2

- ethylhexyl)

phthalate 2,4,6,OR 100 1 50,000 500 5 x 10 6 Ref. 2, p. 2

Cobalt 1,4,5,6,8, OR 10 1 5,000 5,000 5 x 10 4 Ref. 2, p. 3

Lead 3,4,5,6,
OR 10,000 1 5 5,000 5 x 10 7 Ref. 2, p. 8

Manganese 1,2,4,5,6, 7,8,
OR 10,000 1 50,000 50,000 5 x 10 8 Ref. 2, p. 8

Mercury 3, 6, OR 10,000 0.4 000 50,000 50,000 2 x 10 8 Ref. 2, p. 8

2- Methyl

naphthalene 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 10 7 Ref. 2, p. 9

Silver 3,4,OR 100 1 50 50,000 5 x 10 6 Ref. 2, p. 10

Vanadium 3,4,5,6, 7,OR 100 1 500 500 5 x 10 4 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 haz ardous substances persistence factor value (Ref. 1, Sect. 4.1.2.2.1.2). The persistence values were assigned for a river accordin g 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” i n which the fisheries are located. The data that yielded the higher factor value was assigned to t he Bioaccumulation Factor Value of the hazardous substance (Ref. 1, Sect. 4.1.3.2.1.3).


### Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 10 8

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### 88 September 2012 T XN000607093SW Pathway

– Human Food Chain Threat/Waste Characteristics



### 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 s ection 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 Va lue: 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 10 6 

### (subject to a maximum of 1 x 10 8 

### )

(Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x (Bioaccumulation Potential Factor Value) = 5 x 10 10



### 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 has 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 pr oduct of 5 x 10 10 

### is 320.

Hazardous Waste Quantity Assigned Value: 100

Waste Characteristics Factor Category Value: 320

HRS Documentation Record US Oil Recovery 

### 89 September 2012 T XN000607093SW Pathway – Human Food Chain Threat/Waste Characteristics



### 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 Section s 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 Bayo u 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 f rom 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 10 4
5 x 10 8
5 x 10 4

SW

- 09 (MF3SF7/MF3SF6) 620 Mercury Silver 5 x 10 8 5,000

SW

- 08 (MF3S J0 ) 895 Barium Lead Mercury

Silver 5 x 10 6
5 5 x 10 8 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 10 8 5,000
SW

- 04 (MF3S H7 /MF3SH6) 1,945 Arsenic Mercury 5 x 10 4
5 x 10 8

SW

- 03 (MF3S H4 /MF3S H5 ) 2,135 Mercury Silver 5 x 10 8 5,000

PPE

- 01 (MF3SH3/MF3S H2 ) 2,285 Arsenic Mercury

Silver 5 x 10 4
5 x 10 8 5,000
SW

- 02 (MF 3SG4 ) 2,375 Arsenic Mercury 5 x 10 4
5 x 10 8

SW

- 01 * (SED

- 01

- 03

- 51) 2,475 Arsenic Bis(2

- ethylhexyl)phthalate 5 x 10 4 50,000

* SW

- 01 is the farthest downstream sample location

.

HRS Documentation Record US Oil Recovery 

### 90 T XN000607093SW Pathway – Human Food Chain Threat/Waste Characteristics



### - 

### Closed Fisheries

No fisheries within the surface water pathway have been closed due to contamination from the USOR site

.

- Benthic o r Other Tissue

No benthic or other tissue samples have been collected from the surface water pathway.

HRS Documentation Record US Oil Recovery 

### 91 T XN000607093SW Pathway – Human Food Chain Threat/Waste Characteristics



### 4.5. 1 Food Chain Individual

F ishing is documented within the TDL off the N. Richey Street bridge ( Ref. 6, p. 105; Ref. 17; Attachment A, Figure A -3). At this locati on, 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 ar e documented in discharges, surface water, and/or sediment samples located within this fishery to sample location (SW

01) (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 w ithin 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) Reference s 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. 3 4 , 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).

HRS Documentation Record US Oil Recovery 

### 92 T XN000607093SW Pathway – Human Food Chain Threat/Waste Characteristics



### 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 (P i ) Dilution Weight (D i ) P i x D i 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. 0 03

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. 3 7 , pp. 1 -2 ). Data to

es timate 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 P i 

### x D i 

### = 0.03 x 0.1

Product of P i 

### x D i 

### : 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 P i 

### x D i 

### = 0.03 x 0.001

Product of P i 

### x D i 

### : 0.00003

(Sum of Products of P i 

### x D i 

### )/10: 0.000303

HRS Documentation Record US Oil Recovery 

### 93 T XN000607093SW 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 Persistence 1
Factor Value Ecosystem Bioaccumulation Potential Factor Value
Fresh 2 Ecosystem Bioaccumulation Potential Factor Value
Salt 2 Ecotoxicity/ Persistence/ Bioaccumulation

Factor Value Reference

Arsenic 3,4,7,OR 10 0 1 5,000 500 5 x 10 5 Ref. 2, p.1 Bis(2

- ethylhexyl)
Phthalate 2,4,6,OR 1,000 1 50,000 5,000 5 x 10 7 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 10 7 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 0.4000 50,000 50,000 2 x 10 8 Ref. 2, p. 8

2- Methyl

naphthalene 1,2,4,5,6, OR 100 0 0.4000 50,000 50,000 2 x 10 7 Ref. 2, p. 9 Naphthalene 1,2,3,4,5, 6
OR 1,000 0.4000 50,000 5,000 2 x 10 7 Ref. 2, p. 9

Silver 3,4,OR 10,000 1 50 50,000 5 x 10 8 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 haz ardous substances persistence factor value (Ref. 1, Sec. 4.1.2.2.1.2). The persistence values were assigned f or 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 yield ed 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 10 8

HRS Documentation Record US Oil Recovery 

### 94 September 2012 T XN000607093SW 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 Section s 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 10 6 

### ( Ecotoxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x (Bioaccumulation Potential Factor Value) = 5 x 10 10 

### (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, silver has a n eco 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 10 10 

### is 320.

Hazardous Waste Quantity Assigned Value: 100

Waste Characteristics Factor Category Value: 320

HRS Documentation Record US Oil Recovery 

### 95 September 2012 T XN000607093SW Pathway – Environmental Threat/Targets



### 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 exten d s 2,475 feet from PPE

- 06A in Vince Bayou to the fa rthest 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 w as 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 wet lands on opposite banks of the stream are considered separate wetlands . T he 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 f ee t + 840 f ee t + 330 feet = 1,720 f ee t) ( 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 Front age along Vince Bayou = 1,720 feet (0. 3257 miles)

Wetland Value (Ref. 1, Table 4-24): 25

Level II Concentrations Factor Value: 25

HRS Documentation Record US Oil Recovery 

### 96 T XN000607093Soil Exposure Pathway – Not Sco red



### 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.

HRS Documentation Record US Oil Recovery 

### 97 T XN000607093

### A TTACHMENT AUSOR

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 AS SHOWN APR. 2011 

# £ 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

20406.012.019.0612.01FIGURE 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 PondRolloff Boxes Rolloff

Boxes Rolloff Boxes

Rolloff Boxes Rolloff Boxes

Rolloff Boxes Main Office Warehouse

Container Storage Area

Machine Shop Lab

SCALE DATE PROJECT NO 

## 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 

# £ 0 160 80

SCALE IN FEETFIGURE 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 #1 Clarifier #2

Gravity Thickener Aerobic Digester

Primary Clarifier High Rate Trickling

FilterN. Richey St W. Richey St Pump Control Room Oxygen Activated Sludge Tank (Aeration Basin)

Aeration Basin (Final Clarifier) Vince Bayou

SCALE DATE PROJECT NO 

## US EPA REGION 6 START-3 Legend

APPROXIMATE PIPELINE LOCATION

SOURCE 4 OVERLAND FLOW PATH

FENCED PROPERTY BOUNDARY 

# £ 0 180 90

SCALE IN FEETPPE-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 0 500 250

SCALE IN FEET LEVEL II DOCUMENTED FISHING AREA (HUMAN FOOD CHAIN ZONE OF CONTAMINATION) ZONE OF CONTAMINATION FOR ENVIRONMENTAL THREATS